OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION. MEMORANDUM February 25, 2011

Transcription

1 OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION DRAFT MEMORANDUM February 25, 2011 TO: THROUGH: THROUGH: THROUGH: FROM: SUBJECT: Phillip Fielder, Permits and Engr. Group Mgr., Air Quality Division Kendal Stegmann, Senior Environmental Manager, Compliance and Enforcement Phillip Martin, P.E., Engineering Section Peer Review Kyle Walker, Existing Source Permits Section Evaluation of Operating Permit Application No O Whiting Oil and Gas Corporation West Hough Morrow Unit (WHMU) Section 35, T5N, R13ECM, Texas County Location: from Guymon, proceed 10.5 miles north and back west on Hwy 3 and 64 to Goodwell Road; then 7 miles north on Goodwell Road to Road J; east on Road J one mile (mile marker 22.1). Physical address is: County Road 7 & Goodwell Road (Road G, mile marker 21). SECTION I. INTRODUCTION Whiting Oil and Gas Corporation (Whiting) has submitted an operating permit application for the referenced facility (SIC 1311). This facility is an oil production/separation facility and a water injection station combined at the same site (SIC 1311). This facility is currently operating under Permit No TV issued July 7, The facility removed two internal combustion engines at the facility and reduced its facility-wide emissions below major source thresholds. Whiting has requested a synthetic minor operating permit for the facility. This permit modification includes the following: Whiting has installed electric driven compressors in place of the previously permitted units (ENG-6 and ENG-7). Whiting requests that the engines be removed from the permit. Whiting has reduced potential flaring event emissions. Whiting has reduced the annual limit to 800 MMSCF and requests the short term limit is removed from the permit. Include blowdown emissions in the emissions inventory. Include emissions from the emergency generator in the emissions inventory. Update storage tank emissions. Include loadout emissions. Update process piping fugitive emissions.

2 PERMIT MEMORANDUM O DRAFT 2 The facility-wide emissions are less than major source thresholds of 100 TPY for criteria pollutants, 25 TPY total hazardous air pollutants (HAPs), and 10 TPY individual HAP emissions. Based on current emissions the facility is a synthetic minor source. SECTION II. FACILITY DESCRIPTION This facility formerly had two compressor engines. The engines that were permitted have been removed. The compressor engines were replaced with electric motors. There are four oil tanks at the site: one 690-barrel (28,980-gallon) sales tank, one 690-barrel standby tank, one 690-barrel bad tank, and one 210-bbl (8,820-gallon) crude tank. Additionally, there are eight water tanks, one 3.0 MMBtu/hr heater treater, one flare, and one emergency generator. This is an oil production/separation facility and a water injection station combined at the same site. Permitting is required due to emissions from the storage tanks. Whiting currently has secondary and CO 2 recovery operations ongoing in the West Hough Morrow Unit. Produced fluids (oil, water and emulsion) are piped to the West Hough Morrow Central Tank Battery for separation. The oil is sold through a Lease Automatic Custody Transfer (LACT) unit at the site. Separated water and water trucked in from supply wells is stored in eight water storage tanks prior to reinjection or disposal. Injection tanks feed two water injection pumps driven by electric motors. The produced fluid entering the battery consists of an emulsion, typically 95% water and 5% oil, which is sent to a free-water knockout vessel and then to a heater/treater for emulsion breaking. The fuel for the treater is also sweet gas. The produced oil is sent to a 690-bbl tank (TNK-1A). The second 690-bbl tank (TNK-2A) is a bad oil tank where oil needing further emulsion treating is sent and then recycled to the heater/treater. The third 690-bbl tank (TNK-3A) is a standby tank. All tank vents are routed to a vapor recovery unit, and the recovered vapors are sent to the nearby gas plant, as is the gas from the free-water knockout and the heater/treater. Piping fugitives consist of valves, flanges, connectors, and pump seals. There is one combination process/emergency flare so that excess produced gases can be routinely flared as necessary to support the Enhanced Oil Recovery (EOR) Program being conducted in the Postle Field. As a result of the EOR Program, CO 2 is the primary component (approximately 90%) of the gas being produced from the wells. Produced gases are delivered to a nearby plant for processing, but the plant lacks the capacity to process all of the gas being produced because of design limitations. SECTION III. PREVIOUSLY PERMITTED EQUIPMENT EUG 1 Internal Combustion Engines EU ID# Point ID# EU Name/Model Serial No. Const.Date E-ENG6 ENG hp Caterpillar G398 engine w/cc 73B E-ENG7 ENG-7 1,085-hp Caterpillar G3516TALE 3RC

3 PERMIT MEMORANDUM O DRAFT 3 EUG 2 Storage Tanks EU ID# Point ID# Contents Capacity Construction Barrels Gallons Date E-TNK1A TNK-1A Crude Oil , E-TNK2A TNK-2A Crude Oil , E-TNK3A TNK-3A Crude Oil , E-TNK7 TNK-7 Corrosion Inhibitor Unknown E-TNK8 TNK-8 Demulsifier Unknown E-TNK9, 10 TNK-9, 10 Antifreeze < 4.5 < 190 Unknown E-TNK11, 12 TNK-11, 12 Empty 1 50 Unknown EUG 3 Heater EU ID# Point ID# Equipment Capacity (MMBtu/hr) Const. Date E-HT1 HT-1 Heater Treater EUG 4 Flare EU ID# Point ID# Equipment Capacity (MMSCFD) Const. Date E-FL1 FL-1 Process Flare EUG 5 Fugitive VOC Emission Sources EU Component Service Approx. # Components E-FUG Valves Gas 44 Valves Light Liquid 44 Valves Heavy Liquid 84 Pump Seals Light Liquid 4 Flanges Gas 149 Flanges Light Liquid 122 Flanges Heavy Liquid 204 Connectors Gas 239 Connectors Light Liquid 157 Connectors Heavy Liquid 141 SECTION IV. CURRENTLY PERMITTED EQUIPMENT Generator Engine Point ID# EU Name/Model Installation Date GEN 300-hp Chevrolet 350 emergency generator engine 1995 Storage Tanks Point ID# Contents Capacity Construction (Barrels) (Gallons) Date TNK-1A Crude Run Oil , TNK-2A Bad Oil , TNK-3A Standby Oil , TNK4 Skim Tank 210 8,820 n/a

4 PERMIT MEMORANDUM O DRAFT 4 Storage Tanks (Continued) Point ID# Contents Capacity Construction (Barrels) (Gallons) Date TW1 Produced Water ,500 n/a TW2 Produced Water ,500 n/a TW3 Produced Water ,500 n/a TW4 Produced Water ,500 n/a TW5 Produced Water ,500 n/a TW6 Raw Water 1,400 58,800 n/a TW7 Water Transfer 1,000 42,000 n/a TW8 Water Disposal ,000 n/a Truck Loading Point ID# Source Throughput (gal/yr) L-1 Truck Loading 500,000 Heater Point ID# Equipment Capacity (MMBtu/hr) Installation Date HT-1 Heater Treater Flare Point ID# Equipment Installation Date FL-1 Process/Emergency Flare 2004 Process Piping Fugitive VOC Emission Sources Point ID# Equipment Gas Liquid P-FUG Valves Pump Seals Flanges Compressor Seals Relief Valves Connectors SECTION V. AIR EMISSIONS Compressor and mud mixer engines were replaced with electric motors. There are no regulated emissions from electric motors. Engine emissions for the 300-hp Chevrolet 350 emergency generator engine were calculated based on 500 hours per year operation, AP-42 emission factors for uncontrolled natural gas-fired rich burn engines (table 3.2-3), and 2.40 MMBtu/hr heat input. Engine Emission Factors Emission Factors (lb/mmbtu) EU ID# NO X CO VOC GEN

5 PERMIT MEMORANDUM O DRAFT 5 Tank working and breathing losses were calculated using the EPA TANKS 4.09 program, with a throughput of 91,980,000 gallons per year. Vapor recovery efficiency of 98% was also assumed for tank emission calculations. Loadout emissions are calculated using methods of AP-42 (1/95), Section 5.2 and 500,000 gallons per year throughput. Tank flash emissions were calculated using the Aspen HYSIS process simulation with 98% collection efficiency from the vapor recovery system. Fugitive emissions of VOCs were calculated using the USEPA document, Protocol for Equipment Leak Estimates (EPA-453/r95-017) and estimated equipment component counts. Emissions from the heater treater are based on AP-42 (7/98) Tables & 2. NO X and CO emissions from the flare were calculated using emission factors from AP-42 Table VOC emissions were derived for the flare using a gas analysis, gas throughput, mass balance equations, and 98% destruction efficiency. SO 2 emissions were derived for the flare using a gas analysis, gas throughput, and mass balance equations. Flare gas throughput is limited to 800 MMSCF/year. Blowdown emissions were calculated using a mass balance equation. Whiting uses 10,000 SCF of gas expelled per blowdown event as a conservative estimate. The gas contains 18.08% VOC by mass from an extended gas analysis with contingency added. Annual VOC emissions from blowdown events are calculated by multiplying the total volume of blowdowns, dividing by the volume of gas per pound-mole, multiplying by pound mass of gas per pound-mole, multiplying by percent VOC in the gas, and converting pounds to tons. Annual Blowdown Emissions Calculation [600,000(SCF/yr)/380(SCF/lb-mol)]*20.48(lb/lb-mol)*18.08% VOC /2,000(lb/ton) = 2.92 TPY VOC Previous Facility-Wide Emissions EU NOx CO VOC SO 2 lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY E-ENG E-ENG TNK-1A TNK-2A TNK-3A E-FUG HT FL Total Uncontrolled Current Facility-Wide Emissions EU ID# Source NO X CO VOC SO 2 lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY TNK-1A Sales Oil, 690 bbl TNK-2A Standby Oil, 690 bbl

6 PERMIT MEMORANDUM O DRAFT 6 Uncontrolled Current Facility-Wide Emissions (continued) EU ID# Source NO X CO VOC SO 2 lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY TNK-3A Waste Oil, 690 bbl TNK4 Skim Tank, 210 bbl TW1 Produced Water, 750 bbl TW2 Produced Water, 750 bbl TW3 Produced Water, 750 bbl TW4 Produced Water, 750 bbl TW5 Produced Water, 750 bbl TW6 Raw Water, 1,400 bbl TW7 H 2 O Transfer, 1,000 bbl TW8 Water Disposal, 500 bbl FLASH Tank Flashing GEN hp Chevrolet Gen L-1 Truck Loading 0.51 HT-1 Heater treater < FL-1 2 Process/Emergency Flare BLOW Compressor Blowdowns 2.92 P-FUG Piping Fugitives TOTAL < Based on 500 hours per year operation. 2 Based on 800 MMSCF/year throughput. Controlled Current Facility-Wide Emissions EU ID# Source NO X CO VOC SO 2 lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY TNK-1A Sales Oil, 690 bbl TNK-2A Standby Oil, 690 bbl TNK-3A Waste Oil, 690 bbl TNK4 Skim Tank, 210 bbl TW1 Produced Water, 750 bbl TW2 Produced Water, 750 bbl TW3 Produced Water, 750 bbl TW4 Produced Water, 750 bbl TW5 Produced Water, 750 bbl TW6 Raw Water, 1,400 bbl TW7 Water Transfer, 1,000 bbl TW8 Water Disposal, 500 bbl FLASH Tank Flashing GEN hp Chevrolet Gen L-1 Truck Loading 0.51 HT-1 Heater treater < VOC emissions include breathing, working, and flashing tank emissions combined. 2 Based on 500 hours per year operation.

7 PERMIT MEMORANDUM O DRAFT 7 Controlled Current Facility-Wide Emissions (continued) EU ID# Source NO X CO VOC SO 2 lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY FL-1 3 Process/Emergency Flare BLOW Compressor Blowdowns 2.92 P-FUG Piping Fugitives TOTAL < Based on 800 MMSCF/year throughput. Difference in Facility-Wide Emissions NO X CO VOC SO 2 TPY TPY TPY TPY Previous Emissions Current Emissions Emissions Change The internal combustion engine will have emissions of hazardous air pollutants (HAPs), the most significant being formaldehyde. Potential formaldehyde emissions calculations for the Chevrolet 350 engine is based on the uncontrolled 4-stroke rich-burn engine factor of lb/mmbtu from AP-42 (7/00), Section 3.2, with a heat input of 2.40 MMBtu/hr. Total formaldehyde emissions are below major source levels. Engine Formaldehyde Emissions Formaldehyde Source lb/hr TPY 300-hp Chevrolet 350 Emergency Generator Engine Total HAP emissions are below major source levels. SECTION VI. OKLAHOMA AIR POLLUTION CONTROL RULES OAC 252:100-1 (General Provisions) [Applicable] Subchapter 1 includes definitions but there are no regulatory requirements. OAC 252:100-2 (Incorporation by Reference) [Applicable] This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal Regulations listed in OAC 252:100, Appendix Q. These requirements are addressed in the Federal Regulations section. OAC 252:100-3 (Air Quality Standards and Increments) [Applicable] Subchapter 3 enumerates the primary and secondary ambient air quality standards and the significant deterioration increments. At this time, all of Oklahoma is in attainment of these standards.

8 PERMIT MEMORANDUM O DRAFT 8 OAC 252:100-5 (Registration, Emissions Inventory, and Annual Operating Fees) [Applicable] Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission inventories annually, and pay annual operating fees based upon total annual emissions of regulated pollutants. Emission inventories were submitted and fees paid for previous years as required. OAC 252:100-7 (Permits for Minor Facilities) [Applicable] Subchapter 7 sets forth the permit application fees and the basic substantive requirements of permits for minor facilities. Since criteria pollutant emissions are less than 100 TPY for each pollutant, and emissions of Hazardous Air Pollutants (HAP) will not exceed 10 TPY for any individual HAP or 25 TPY for any aggregate of HAP, the facility is defined as a minor source. As such, BACT is not required. OAC 252:100-9 (Excess Emission Reporting Requirements) [Applicable] Except as provided in OAC 252: (a)(1), the owner or operator of a source of excess emissions shall notify the Director as soon as possible but no later than 4:30 p.m. the following working day of the first occurrence of excess emissions in each excess emission event. No later than thirty (30) calendar days after the start of any excess emission event, the owner or operator of an air contaminant source from which excess emissions have occurred shall submit a report for each excess emission event describing the extent of the event and the actions taken by the owner or operator of the facility in response to this event. Request for affirmative defense, as described in OAC 252: , shall be included in the excess emission event report. Additional reporting may be required in the case of ongoing emission events and in the case of excess emissions reporting required by 40 CFR Parts 60, 61, or 63. OAC 252: (Open Burning) [Applicable] Open burning of refuse and other combustible material is prohibited except as authorized in the specific examples and under the conditions listed in this subchapter. OAC 252: (Particulate Matter (PM)) [Applicable] Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment, with emission limits based on maximum design heat input rating. Appendix C specifies a PM emission limitation of 0.60 lbs/mmbtu for all equipment at this facility with a heat input rating of 10 Million BTU per hour (MMBTUH) or less. Fuel-burning equipment is defined in OAC 252: as any internal combustion engine or gas turbine, or other combustion device used to convert the combustion of fuel into usable energy. AP-42 (7/98) Table lists natural gas total PM emissions to be 7.6 lbs/million scf or about lbs/mmbtu, which is in compliance. AP- 42 (7/00), Sec. 3.2 lists the total PM emissions from uncontrolled 4-stroke rich-burn natural gasfired engines to be lbs/mmbtu. This permit requires the use of natural gas for the emergency generator and the heater treater to ensure compliance with Subchapter 19. OAC 252: (Visible Emissions and Particulates) [Applicable] This subchapter states that no person shall allow the discharge of any fumes, aerosol, mist, gas, smoke, vapor, particulate matter, or any combination thereof exhibiting greater than 20% opacity except for short term occurrences, which consist of not more than one six-minute (6) period in

9 PERMIT MEMORANDUM O DRAFT 9 any consecutive 60 minutes, not to exceed three such periods in any consecutive 24-hour period. In no case shall the average of any six-minute (6) period exceed 60% opacity. OAC 252: (Fugitive Dust) [Applicable] No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the property line on which the emissions originate in such a manner as to damage or to interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or interfere with the maintenance of air quality standards. Under normal operating conditions, this facility will not cause a problem in this area, therefore it is not necessary to require specific precautions to be taken. OAC 252: (Sulfur Compounds) [Applicable] Part 5 limits sulfur dioxide emissions from new petroleum or natural gas process equipment (constructed after July 1, 1972). For gaseous fuels the limit is 0.2 lb/mmbtu heat input averaged over 3 hours. This is equivalent to approximately 0.2 weight percent sulfur in the fuel gas, which is equivalent to 2,000 ppmw sulfur. Thus, a limitation of 343 ppmv sulfur in a field gas supply will be in compliance. The permit requires the use of pipeline-grade natural gas or field gas with a maximum sulfur content of 343 ppmv. Part 5 also limits hydrogen sulfide emissions from new petroleum or natural gas process equipment (constructed after July 1, 1972). Removal of hydrogen sulfide in the exhaust stream, or oxidation to sulfur dioxide, is required unless hydrogen sulfide emissions would be less than 0.3 lb/hr for a two-hour average. Hydrogen sulfide emissions shall be reduced by a minimum of 95% of the hydrogen sulfide in the exhaust gas. Direct oxidation of hydrogen sulfide is allowed for units whose emissions would be less than 100 lb/hr of sulfur dioxide for a two-hour average. All emissions from the heater treater are vented to the plant flare for conversion of hydrogen sulfide to sulfur dioxide at an efficiency of 98%. The permit will require the flare to be equipped with an alarm to signal non-combustion of the exhaust gases. The permit will also require the facility to measure and record annually the H 2 S concentration of the gas combusted in the flare. OAC 252: (Nitrogen Oxides) [Not Applicable] This subchapter limits new gas-fired fuel-burning equipment with rated heat input greater than or equal to 50 MMBTUH to emissions of 0.2 lb of NO X per MMBTU. There are no equipment items that exceed the 50 MMBTUH threshold. OAC 252: (Carbon Monoxide) [Not Applicable] This facility has none of the affected sources: gray iron cupola, blast furnace, basic oxygen furnace, petroleum catalytic cracking unit or petroleum catalytic reforming unit. OAC 252: (Volatile Organic Compounds) [Applicable] Part 3 requires storage tanks constructed after December 28, 1974, with a capacity of 400 gallons or more and storing a VOC with a vapor pressure greater than 1.5 psia to be equipped with a permanent submerged fill pipe or with an organic vapor recovery system. The three crude oil tanks are equipped with a vapor recovery system. Part 3 requires loading facilities with a throughput equal to or less than 40,000 gallons per day to be equipped with a system for submerged filling of tank trucks or trailers if the capacity of the

10 PERMIT MEMORANDUM O DRAFT 10 vehicle is greater than 200 gallons. This facility does not have the physical equipment (loading arm and pump) to conduct this type of loading. Therefore, this requirement is not applicable. Part 5 limits the VOC content of coating of parts and products. This facility does not normally conduct coating or painting operations except for routine maintenance of the facility and equipment which is exempt and considered a Trivial Activity. Part 7 requires fuel-burning and refuse-burning equipment to be operated to minimize emissions of VOC. The equipment at this location is subject to this requirement. Temperature and available air must be sufficient to provide essentially complete combustion. Part 7 requires all effluent water separator openings, which receive water containing more than 200 gallons per day of any VOC, to be sealed or the separator to be equipped with an external floating roof or a fixed roof with an internal floating roof or a vapor recovery system. The freewater knockout unit is a sealed vessel that is equipped with a vapor recovery system. OAC 252: (Toxic Air Contaminants (TAC)) [Applicable] This subchapter regulates toxic air contaminants (TAC) that are emitted into the ambient air in areas of concern (AOC). Any work practice, material substitution, or control equipment required by the Department prior to June 11, 2004, to control a TAC, shall be retained, unless a modification is approved by the Director. Since no AOC has been designated there are no specific requirements for this facility at this time. OAC 252: (Testing, Monitoring, and Recordkeeping) [Applicable] This subchapter provides general requirements for testing, monitoring and recordkeeping and applies to any testing, monitoring or recordkeeping activity conducted at any stationary source. To determine compliance with emissions limitations or standards, the Air Quality Director may require the owner or operator of any source in the state of Oklahoma to install, maintain and operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant source. All required testing must be conducted by methods approved by the Air Quality Director and under the direction of qualified personnel. A notice-of-intent to test and a testing protocol shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests. Emissions and other data required to demonstrate compliance with any federal or state emission limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained, and submitted as required by this subchapter, an applicable rule, or permit requirement. Data from any required testing or monitoring not conducted in accordance with the provisions of this subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive use, of any credible evidence or information relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed. SECTION VII. FEDERAL REGULATIONS PSD, 40 CFR Part 52 [Not Applicable] PSD does not apply. Final total emissions are less than the threshold of 250 TPY of any single regulated pollutant and the facility is not one of the listed stationary sources with an emission threshold of 100 TPY.

11 PERMIT MEMORANDUM O DRAFT 11 NSPS, 40 CFR Part 60 [Not Applicable] Subpart Kb, VOL Storage Vessels. This subpart regulates hydrocarbon storage tanks with a capacity larger than 19,812-gal (75 m 3 ) and built after July 23, The three crude oil storage tanks are used prior to custody transfer as defined by the subpart, thus they are exempt. Subpart GG, Stationary Gas Turbines. There are none at this facility. Subpart VV, Equipment Leaks of VOC in the Synthetic Organic Chemical Manufacturing Industry. The equipment is not in a SOCMI plant. Subpart KKK, Equipment Leaks of VOC from Onshore Natural Gas Processing Plants. The facility does not engage in natural gas processing. Subpart LLL, Onshore Natural Gas Processing: SO 2 Emissions. This subpart affects sweetening units and sweetening units followed by a sulfur recovery unit which commence construction or modification after January 20, There is no sweetening unit at this facility. Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines, affects stationary compression ignition (CI) internal combustion engines (ICE) based on power and displacement ratings, depending on date of construction, beginning with those manufactured after April 1, For the purposes of this subpart, the date that construction commences is the date the engine is ordered by the owner or operator. There are no CI engines at this facility Subpart JJJJ, Stationary Spark Ignition (SI) Internal Combustion Engines (ICE). This subpart was published in the Federal Register on January 18, It promulgates emission standards for new SI engines ordered after June 12, 2006, that are manufactured after certain dates, and for all SI engines modified or reconstructed after June 12, 2006, regardless of size. The specific emission standards (either in g/hp-hr or as a concentration limit) vary based on engine class, engine power rating, lean-burn or rich-burn, fuel type, duty (emergency or non-emergency), and manufacture date. Engine manufacturers are required to certify certain engines to meet the emission standards and may voluntarily certify other engines. An initial notification is required only for owners and operators of engines greater than 500 HP that are non-certified and are subject to emission standards. The emergency generator engine at this facility was manufactured prior to the applicability date and is not subject to Subpart JJJJ. NESHAP, 40 CFR Part 61 [Not Applicable] There are no emissions of any of the regulated pollutants: arsenic, asbestos, benzene, beryllium, coke oven emissions, mercury, radionuclides, or vinyl chloride except for trace amounts of benzene. Subpart J, Equipment Leaks of Benzene, concerns only process streams that contain more than 10% benzene by weight. Analysis of Oklahoma natural gas indicates a maximum benzene content of less than 1%. NESHAP, 40 CFR Part 63 [ZZZZ Applicable] Subpart HH, Oil and Natural Gas Production Facilities. This subpart applies to affected emission points that are located at facilities that are major and area sources of HAP, and either process, upgrade, or store hydrocarbon liquids prior to custody transfer or that process, upgrade, or store natural gas prior to entering the natural gas transmission and storage source category. This facility is not a major source of HAPs and does not have a glycol dehydration unit. Subpart ZZZZ, Reciprocating Internal Combustion Engines (RICE). This subpart affects RICE with a site-rating greater than 500 brake horsepower that are located at a major source and new and reconstructed engines (after June 12, 2006) with a site rating less than or equal to 500 HP

12 PERMIT MEMORANDUM O DRAFT 12 located at major sources, and located at area sources. Owners and operators of new or reconstructed engines at area sources and of new or reconstructed engines with a site rating equal to or less than 500 HP located at a major source (except new or reconstructed 4-stroke lean-burn engines with a site rating greater than or equal to 250 HP and less than or equal to 500 HP located at a major source) must meet the requirements of Subpart ZZZZ by complying with either 40 CFR Part 60 Subpart IIII (for CI engines) or 40 CFR Part 60 Subpart JJJJ (for SI engines). Based on emission calculations, this facility is a minor source of HAP. The engine was manufactured prior to July 1, 2007 and has not been modified or reconstructed and is considered an existing engine. On August 20, 2010, EPA finalized additional requirements for stationary SI RICE located at area sources. A summary of these requirements for the emergency generator engine located at this facility are shown below. Engine Category Normal 15% O 2 Existing Emergency SI & Black Start CI Change oil and filter every 500 hours of operation or annually, whichever one comes first; Inspect spark plugs every 1,000 hours of operation or annually, whichever one comes first; and Inspect all hoses and belts every 500 hours of operation or annually, whichever one comes first and replace as necessary. Initial notification is not required for an existing stationary emergency RICE. The facility must comply with this subpart by the initial compliance date of October 19, Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable] This facility will not process or store more than the threshold quantity of any regulated substance (Section 112r of the Clean Air Act 1990 Amendments). More information on this federal program is available on the web page: SECTION VIII. COMPLIANCE Tier Classification and Public Review This application has been determined to be a Tier II based on the request for changing a Title V operating permit to a synthetic minor source operating permit. The permittee has submitted an affidavit that they are not seeking a permit for land use or for any operation upon land owned by others without their knowledge. The affidavit certifies that the applicant possesses a current lease or easement given by the landowner for the purpose or purposes stated in the application. The applicant published the Notice of Filing a Tier II Application in The Guymon Daily Herald, a daily newspaper, in the city of Guymon, Texas County, on January 13, The notice stated that the application was available for public review at the Guymon Public Library and at the Oklahoma City DEQ Air Quality Division main office. The applicant will publish the Notice of Draft Permit in a newspaper in Texas County. The notice will state that the draft permit is available for public review for a period of 30 days within the county and at the Air

13 PERMIT MEMORANDUM O DRAFT 13 Quality Division main office and on the Air Quality section of the DEQ web page at This facility is located within 50 miles of the Oklahoma-Kansas and the Oklahoma-Texas borders. Kansas and Texas will be notified of this draft permit. EPA Review The proposed permit will be forwarded to EPA for a 45-day review period after public review. Inspection A full compliance evaluation was conducted at the Whiting - West Hough Morrow Station on October 23, Preston Loving, Jaron Hill, Holly Taber, and Keely Dolan, Environmental Programs Specialists, conducted the evaluation for the Air Quality Division of the Oklahoma Department of Environmental Quality. Gary Wright, Operations Supervisor; Roger Valliquette, Production Supervisor; and Nina Palmer, EH&S Coordinator, represented the Facility. Based on the information provided or obtained during this evaluation, no compliance issues were discovered. Testing The 300-hp Chevrolet 350 emergency generator engine at this facility is an existing source and not required to conduct initial emission testing. Fees Paid Significant modification to a Title V operating permit fee of $1,000. SUMMARY The applicant has demonstrated the ability to comply with the applicable Air Quality rules and regulations. Ambient air quality standards are not threatened at this site. There is no other active Air Quality compliance or enforcement action concerning this facility that would affect the issuance of this permit. Issuance of the operating permit is recommended, contingent on public and EPA review.

14 PERMIT TO OPERATE AIR POLLUTION CONTROL FACILITY SPECIFIC CONDITIONS Whiting Oil and Gas Corporation West Hough Morrow Unit Permit No O The permittee is authorized to operate in conformity with the specifications submitted to Air Quality on January 8, 2010, and subsequent information. The Evaluation Memorandum dated February 25, 2011 explains the derivation of applicable permit requirements and estimates of emissions; however, it does not contain operating limitations or permit requirements. Continuing operations under this permit constitutes acceptance of, and consent to, the conditions contained herein. 1. Points of emissions and emissions limitations for each point: Facility-Wide Emissions EU ID# Source NO X CO VOC SO 2 lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY TNK-1A Sales Oil, 690 bbl TNK-2A Standby Oil, 690 bbl TNK-3A Waste Oil, 690 bbl TNK4 Skim Tank, 210 bbl TW1 Produced Water, 750 bbl TW2 Produced Water, 750 bbl TW3 Produced Water, 750 bbl TW4 Produced Water, 750 bbl TW5 Produced Water, 750 bbl TW6 Raw Water, 1,400 bbl TW7 Water Transfer, 1,000 bbl TW8 Water Disposal, 500 bbl FLASH Tank Flashing GEN hp Chevrolet Gen L-1 Truck Loading 0.51 HT-1 Heater treater FL-1 3 Process/Emergency Flare BLOW Compressor Blowdowns VOC emissions include breathing, working, and flashing tank emissions combined. 2 Based on 500 hours per year operation. 3 Based on 800 MMSCF/year throughput. 2. The gaseous fuel-burning equipment shall be fired with pipeline grade natural gas or other gaseous fuel with a sulfur content less than 343 ppmv. Compliance can be shown by the following methods: for pipeline grade natural gas, a current gas company bill; for other gaseous fuel, a current lab analysis, stain-tube analysis, gas contract, tariff sheet, or other approved methods. Compliance shall be demonstrated at least once annually.

15 SPECIFIC CONDITIONS O DRAFT 2 3. The permittee shall be authorized to operate this facility continuously (24 hours per day, every day of the year). 4. The generator engine at the facility shall have a permanent identification plate attached, which shows the make, model number, and serial number. 5. At least once per calendar quarter, the permittee shall conduct tests of NO X and CO emissions in exhaust gases from each engine/turbine when operating under representative conditions for that period. Testing is required for any engine/turbine that runs for more than 220 hours during that calendar quarter. A quarterly test may be conducted no sooner than 20 calendar days after the most recent test. Testing shall be conducted using a portable analyzer in accordance with a protocol meeting the requirements of the latest AQD Portable Analyzer Guidance document, or an equivalent method approved by Air Quality. When four consecutive quarterly tests show the engine/turbine to be in compliance with the emissions limitations shown in the permit, then the testing frequency may be reduced to semi-annual testing. A semi-annual test may be conducted no sooner than 60 calendar days nor later than 180 calendar days after the most recent test. Likewise, when the following two consecutive semi-annual tests show compliance, the testing frequency may be reduced to annual testing. An annual test may be conducted no sooner than 120 calendar days nor later than 365 calendar days after the most recent test. Upon any showing of non-compliance with emissions limitations or testing that indicates that emissions are within 10% of the emission limitations, the testing frequency shall revert to quarterly. Reduced testing frequency does not apply to engines with catalytic converters or oxidation catalysts. 5. The permittee shall keep operation and maintenance (O&M) records for those engines which do not conduct quarterly testing. Such records shall at a minimum include the dates of operation, and maintenance, type of work performed, and the increase, if any, in emissions as a result. 6. The emergency generator is limited to 500 hours per year operation (12 month rolling total). When the emergency generator engine exceeds 500 hours per year operation the permittee shall comply with the provisions of OAC 252:100-9 for excess emissions. Requirements of OAC 252:100-9 include immediate notification and written notification of Air Quality and demonstrations that the excess emissions meet the criteria specified in OAC 252: Replacement (including temporary periods of 6 months or less for maintenance purposes), of the internal combustion engines/turbines with emissions specified in this permit with engines/turbines of lesser or equal emissions of each pollutant (in lbs/hr and TPY) are authorized under the following conditions. a. The permittee shall notify AQD in writing within 10 days of start-up of the replacement engine(s)/turbine(s). Said notice shall identify the old engine /turbine and shall include the new engine/turbine make and model, serial number, horsepower rating, fuel usage, stack flow (ACFM), stack temperature ( F), stack height (feet), stack diameter (inches), and pollutant emission rates (g/hp-hr, lb/hr, and TPY) at maximum horsepower for the altitude/location.

16 SPECIFIC CONDITIONS O DRAFT 3 b. Quarterly emissions tests for the replacement engine(s)/turbine(s) shall be conducted to confirm continued compliance with NO X and CO emissions limitations. A copy of the first quarter testing shall be provided to AQD within 60 days of start-up of each replacement or additional engine/turbine. The test report shall include the engine/turbine fuel usage, stack flow (ACFM), stack temperature ( o F), stack height (feet), stack diameter (inches), and pollutant emissions rates (g/hp-hr, lbs/hr, and TPY) at maximum rated horsepower for the altitude/location. c. Replacement equipment and emissions are limited to equipment and emissions that are not subject to NSPS, NESHAP, or PSD. 8. The permittee shall monitor and document compressor blowdown emissions. For compressor blowdown events, the permittee shall estimate the volume of gas released and compute the tons of VOCs emitted per month and maintain 12-month rolling totals showing tons of VOCs emitted due to compressor blowdowns. 9. The crude oil throughput of the facility shall not exceed 91,980,000 gallons in any 12-month period. 10. Volume of crude oil loaded and unloaded by truck shall not exceed 500,000 gallons in any 12-month period. 11. The free-water knock out tank, heater treater, and each oil tank (TNK1A, TNK2A, and TNK3A) shall be operated with a vapor recovery system with a minimum 98% capture efficiency. 12. The flare shall be installed and operated as follows: a. The flare shall be limited to a maximum of 800 MMSCF of gas flared per any 12-month period. This limit is for flare events and does not include pilot gas. b. The flare shall be equipped with a gas flow monitoring device. c. The flare shall be equipped with a continuous pilot light. d. The amount of gas flared (MMSCF) shall be monitored and recorded (daily, monthly, and 12-month rolling total). e. An extended gas analysis shall be performed annually on the gas entering the flare. f. The flare shall be designed for smokeless operation and be operated using good combustion practices. g. The flare shall be equipped with an alarm to signal non-combustion of the exhaust gases. h. The H 2 S concentration of the gas combusted in the flare shall be measured and recorded annually. 14. The owner/operator shall comply with all applicable requirements of the NESHAP: Reciprocating Internal Combustion Engines, Subpart ZZZZ, for each affected facility including but not limited to: [40 CFR through ] What This Subpart Covers b What is the purpose of subpart ZZZZ? c Am I subject to this subpart?

17 SPECIFIC CONDITIONS O DRAFT 4 d What parts of my plant does this subpart cover? e When do I have to comply with this subpart? Emission and Operating Limitations f What emission limitations and operating limitations must I meet if I own or operate an existing stationary RICE located at an area source of HAP emissions? General Compliance Requirements g What are my general requirements for complying with this subpart? Testing and Initial Compliance Requirements h What are my monitoring, installation, operation, and maintenance requirements? i How do I demonstrate initial compliance with the emission limitations and operating limitations? Continuous Compliance Requirements j How do I demonstrate continuous compliance with the emission limitations and operating limitations? Notifications, Reports, and Records k What reports must I submit and when? l What records must I keep? m In what form and how long must I keep my records? Other Requirements and Information n What parts of the General Provisions apply to me? o Who implements and enforces this subpart? p What definitions apply to this subpart? 15. The permittee shall maintain the following records of operations as listed below. These records shall be maintained on-site or at a local field office for at least five years after the date of recording and shall be provided to regulatory personnel upon request. a. Periodic testing for each permitted engine and replacement engines. b. Operating hours for each engine/turbine if less than 220 hours per quarter and not tested. c. For the fuel(s) burned, the appropriate document(s) as described in Specific Condition 2. d. Summary of O&M records for any engine not tested in each 6 month period. e. The amount of gas flared, MMSCF (monthly and 12-month rolling total). f. The H 2 S content of the gas being flared (annually). g. Total oil throughput for the facility (monthly and 12-month rolling total). h. Volume of crude oil loaded and unloaded by truck (monthly and 12-month rolling total). i. Number of hours if the vapor recovery unit is not in service (monthly and 12-month rolling total). j. Compressor blowdown emissions as described in Specific Condition No. 8 (monthly and 12-month rolling total). k. Records required by NESHAP, Subpart ZZZZ. 16. No later than 60 days after the issuance of this minor operating permit, the permittee shall submit to Air Quality Division of DEQ, with a copy to the US EPA, Region 6, a certification of compliance with the terms and conditions of the Part 70 operating permit for the time period between the most recent certification of compliance and the issuance date of the

18 SPECIFIC CONDITIONS O DRAFT 5 synthetic minor permit. The certification of compliance shall also contain a report of all required monitoring not reported since the last semi-annual monitoring report. 17. This permit supersedes all previous Air Quality permits for this facility, which are now null and void.

19 Whiting Petroleum Corporation Attn: Mr. Jagadeesan Sethuraman 1700 Broadway, Suite 2300 Denver, CO Permit Number: O Permit Writer: Kyle Walker Subject: Facility: West Hough Morrow Unit Location: Texas County, OK Dear Mr. Sethuraman: Enclosed is the permit authorizing operation of the referenced equipment at the facility. Please note that this permit is issued subject to standard and specific conditions, which are attached. These conditions must be carefully followed since they define the limits of the permit and will be confirmed by periodic inspections. Also note that you are required to annually submit an emissions inventory for this facility. An emissions inventory must be completed on approved AQD forms and submitted (hardcopy or electronically) by April 1 st of every year. Any questions concerning the form or submittal process should be referred to the Emissions Inventory Staff at Thank you for your cooperation. If you have any questions, please refer to the permit number above and contact the permit writer at (405) Sincerely, DRAFT Kyle Walker Existing Source Permits Section AIR QUALITY DIVISION

20 PERMIT AIR QUALITY DIVISION STATE OF OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY 707 N. ROBINSON, SUITE 4100 P.O. BOX 1677 OKLAHOMA CITY, OKLAHOMA Permit No O DRAFT Whiting Petroleum Corporation, having complied with the requirements of the law, is hereby granted permission to operate the West Hough Morrow Unit facility located in Section 35, Township 5N, Range 13E in Texas County, Oklahoma, subject to standard conditions dated September 1, 2009, and specific conditions, both attached. DRAFT Division Director, Air Quality Division DRAFT Date DEQ Form # Revised 10/20/06

21 MINOR SOURCE PERMIT TO OPERATE / CONSTRUCT AIR POLLUTION CONTROL FACILITY STANDARD CONDITIONS (September 1, 2009) A. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma Department of Environmental Quality (DEQ) in accordance with and under the authority of the Oklahoma Clean Air Act. The permit does not relieve the holder of the obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or ordinances. This specifically includes compliance with the rules of the other Divisions of DEQ: Land Protection Division and Water Quality Division. B. A duly issued construction permit or authorization to construct or modify will terminate and become null and void (unless extended as provided in OAC 252: (g)) if the construction is not commenced within 18 months after the date the permit or authorization was issued, or if work is suspended for more than 18 months after it is commenced. [OAC 252: (f)] C. The recipient of a construction permit shall apply for a permit to operate (or modified operating permit) within 60 days following the first day of operation. [OAC 252: (a)] D. Unless specified otherwise, the term of an operating permit shall be unlimited. E. Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this facility is required and shall be made in writing by the transferor within 10 days after such date. A new permit is not required. [OAC 252: (f)] F. The following limitations apply to the facility unless covered in the Specific Conditions: 1. No person shall cause or permit the discharge of emissions such that National Ambient Air Quality Standards (NAAQS) are exceeded on land outside the permitted facility. [OAC 252:100-3] 2. All facilities that emit air contaminants are required to file an emission inventory and pay annual operating fees based on the inventory. Instructions and forms are available on the Air Quality section of the DEQ web page. [OAC 252:100-5] 3. All excess emissions shall be reported to the Director of the Air Quality Division as soon as practical during normal office hours and no later than the next working day following the malfunction or release. Within ten (10) business days further notice shall be tendered in writing containing specific details of the incident. [OAC 252:100-9] 4. Open burning of refuse and other combustible material is prohibited except as authorized in the specific examples and under the conditions listed in the Open Burning subchapter. [OAC 252:100-13] 5. No particulate emissions from new fuel-burning equipment with a rated heat input of 10 MMBTUH or less shall exceed 0.6 lbs/mmbtu. [OAC 252:100-19] 6. No discharge of greater than 20% opacity is allowed except for short-term occurrences which consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours. In no case shall the average of any six-minute period exceed 60% opacity. [OAC 252:100-25]

22 MINOR SOURCE STANDARD CONDITIONS September 1, No visible fugitive dust emissions shall be discharged beyond the property line on which the emissions originate in such a manner as to damage or to interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or interfere with the maintenance of air quality standards. [OAC 252:100-29] 8. No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2 lbs/mmbtu. No existing source shall exceed the listed ambient air standards for sulfur dioxide. [OAC 252:100-31] 9. Volatile Organic Compound (VOC) storage tanks built after December 28, 1974, and with a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia or greater under actual conditions shall be equipped with a permanent submerged fill pipe or with an organic material vapor-recovery system. [OAC 252: (b)] 10. All fuel-burning equipment shall at all times be properly operated and maintained in a manner that will minimize emissions of VOCs. [OAC 252: ] G. Any owner or operator subject to provisions of NSPS shall provide written notification as follows: [40 CFR 60.7 (a)] 1. A notification of the date construction (or reconstruction as defined under 60.15) of an affected facility is commenced postmarked no later than 30 days after such date. This requirement shall not apply in the case of mass-produced facilities which are purchased in completed form. 2. A notification of any physical or operational change to an existing facility which may increase the emission rate of any air pollutant to which a standard applies, unless that change is specifically exempted under an applicable subpart or in 60.14(e). This notice shall be postmarked 60 days or as soon as practicable before the change is commenced and shall include information describing the precise nature of the change, present and proposed emission control systems, productive capacity of the facility before and after the change, and the expected completion date of the change. The Administrator may request additional relevant information subsequent to this notice. 3. A notification of the actual date of initial start-up of an affected facility postmarked within 15 days after such date. 4. If a continuous emission monitoring system is included in the construction, a notification of the date upon which the test demonstrating the system performance will commence, along with a pretest plan, postmarked no less than 30 days prior to such a date. H. Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence and duration of any start-up, shutdown, or malfunction in the operation of an affected facility or any malfunction of the air pollution control equipment. [40 CFR 60.7 (b)] I. Any owner or operator subject to the provisions of NSPS shall maintain a file of all measurements and other information required by this subpart recorded in a permanent file suitable for inspection. This file shall be retained for at least five years following the date of such measurements, maintenance, and records. [40 CFR 60.7 (f)] J. Any owner or operator subject to the provisions of NSPS shall conduct performance test(s) and furnish to AQD a written report of the results of such test(s). Test(s) shall be conducted within 60 days after achieving the maximum production rate at which the facility will be operated, but not later than 180 days after initial start-up. [40 CFR 60.8]