. 

# -- 

# .'

APPLICATION FORA PSD/TITLE V SYNTHETIC MINOR AIR QUALITY PERMIT

OWL COMES OUT 7-98 

# PAD OIL & GAS**~.,U** 

# FACILITY.

Bison Engineering, Inc. 1400 11th Avenue

" '.::... 

## Helena,MT (406) www**Dec~mber~28,:l11** 

# r,.-;:. __­



# -



# - -

# •

DAKOTA-J E&P COMPANY, 1.1£

# ~~(g~~\Vl~~ RsubsidiRry ofWiIIiRms 1001 17111 Street, Suite 1200 

## DEC 282011 Denver, CO 80202 303/527·3900 

# 8P-AR December28, 20II

Ms. Kathleen Pasel' Duplicate submittal provided via e-mail to: MinorNSR PermittingCoordinator r8airpennittin&@epa.gov 

# • U.S. EPA, Region 8 1595 Wynkoop Avenue, 8P-AR Denver, CO 80202-1129
Re: Synthetic Minor Source Permit Application for the Owl Comes Out 7-9H Pad
DearMs. Paser: Dakota-3 E&P Company, LLC (Dakota-3) a subsidiary ofWilliams is submitting this Synthetic Minor Source Permit Application for the Owl Comes Out 7-9H Pad. This application is being submitted in accordance with the requirements ofFederal MinorNew Source Review Rule. Do not hesitate to contact me with any questions either by phone at 303-606-4056, or bye-mail at JoDell.Mizoue@Williams.com
. Sincerely, 

### Williams Dakota-3E&P CompO/I)', LLC

# IJ~ 

# • JoDeJl Mizolle, P.E StaffEnvironmental Specialist Attachment
cc: File Joe Gillies Jr. Environmental Director, Environmental Division, 204 W. Main, NewTown, NO 58763-9404 Tex Hall, Chainllan Three Affiliated Tribes, 404 Frontage Road, New Town, NO 58763-9404 (Jetter Only) 

# •

# • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 8 Air Program FEDERAL MINOR NEW SOURCE REVIEW PROGRAM IN INDIAN COUNTRY 

# oEPA CheckList

- AppJication for New Construction (FormNE\Vl 

### Please check all that apply to show how you are using thisform

• Proposed Constructionofa New Facility 

## o Proposed Construction ofNew Equipment at anExisting Facility 

## o Proposed ModificationofanExisting Facility 

## o Other

- PleaseExplain Use ofthisinformation request form is voluntary and not yet approved by the Office ofManagement and Budget 

# • The following is a check list ofthe type ofinformation that Region 8will use to process information on your proposed project. While submittal ofthis form is not required, it does offer details on the information we will use to complete your requested approval and providingthe information requested mayhelp expedite the process. Use ofapplication forms for this program is currently under OfficeofManagementand Budget review and these information request forms will be replaced/updated after that review is completed. Please submit information to following two entities: MinorNSRPermitting Coordinator 

### u.s. EPA, Region 8 1595 Wynkoop Avenue, 8P-AR Denver, CO 80202-1129 TheTribal Environmental Contact for the specific reservation: lfyou need assistance in identifying the appropriate Tribal Environmental Contact and address, pleasecontactthe EPA Region 8 Tribal Air Coordinator: Alexis North, EPA Region 8 Tribal Air Coordinator 303-312-7005 north.alexis@epa.gov
A. 

### GENERALFACILITY INFORMATION 1. (a) CompanyName Dakota-3 E&P Company, LLC 

# • (b) OperatorName Dakota-3 E&P Company, LLC
3. Type ofOperation Oil and Gas Production 6. NAICS Code 213111 2. Facility Name Owl Comes Out 7-9H Pad

4. Portable Source? 

# o Yes 5. Temporary Source? 

## 0 Yes 

## 181 No 

## 181 No 7. SIC Code 1311 8. Physical Address: 1001 17th Street, Suite 1200 Denver, CO 80202 9. Reservation'" , 10. County'" FBIR Mountrail l2a. Quarter Quarter Section* 12b. Section* NWSW 7 . 11a. Latitude'" 

## I 11b. Longitude'" 47.82411 -102.38332 l2c. Township* 12d. Range'" TI50N R91W 

## I 

# •

# • B. PREVIOUS PERMIT ACTIONS (Provide information in this format for each permit that has been issued to this facility. Provide as an attachment ifadditional space is necessary) This section ofthe permit application is not applicable. This application is for a new facility for which no previous permit actions have been taken. Facility Name on the Permit 

### N/A
Permit Number (xx-xxx-xxxxx-xxxx.xx) 

### N/A 

# I Date ofthe Permit Action 

### N/A 

# •



# •

# • C

# . CONTACT INFORMATION



# •



# • Company Contact: JoDell Mizoue 

# ITitle: I StaffEnvironmental i Specialist Mailing Address: ]001 17th Street, Suite ]200Denver, CO 80202 Email Address: JoDe11.Mizoue@Williams.com Telephone Number: (303) 606-4056 FacsimileNumber: (303) 692-8285 Operator Contact (ifdifferent from company contact): Same as above Title Mailing Address
Email Address TelephoneNumber FacsimileNumber Facility Contact: Same as above Title Mailing Address
Email Address TelephoneNumber FacsimileNumber CompHance Contact: Same as above Title Mailing Address
Email Address Telephone Number FacsimileNumber

# • D. ATTACHMENTS Include all ofthe following information (see the attached instructions) ./ FORM SYNMIN

- New Source Review Synthetic MinorLimit Request Form, ifsynthetic minor limits are beingrequested
. ./ Narrativedescription ofthe proposedproduction processes. This description shou1d foHow the flow of the process flow diagramtobe submitted with this application
. ./ Process flow chart identifying all proposed processing, combustion, handling, storage, and emissioncontrol equipment. ./ A list and descriptions ofall proposed emissionunits and air pollution-generating activities
. ./ Type andquantity offuels, including sulfur content offuels, proposed to be used on a daily, annual and maximum hourly basis. 

# • ./ Type and quantity ofraw materials used or final product produced proposedtobeused ona daily, annual and maximum hourly basis
. ./ Proposed operating schedule, including number ofhours perday, numberofdays perweekand number of weeks per year. ./ A list and description ofall proposed emissioncontrols, control efficiencies, emission limits, and monitoring for each emission unit and air pollution generating activity
. ./ CriteriaPoUutantEmissions

- Estimates ofCurrent Actual Emissions, Current Allowable Emissions, PostChange Uncontrolled Emissions, andPost-Change AllowableEmissions forthe following airpollutants: particulate matter, PMIO, PM2.5, sulfur oxides (SOx), nitrogen oxides (NOx), carbon monoxide (CO), volatile organic compound (VOC), lead (Pb) and leadcompounds, fluorides (gaseous andparticulate), sulfuric acid mist (H2S04), hydrogen sulfide (H2S), total reduced sulfur (TRS) andreduced sulfur compounds, including all calculations for the estimates
. ./ These estimates are to bemadefor each emissionunit, emissiongenerating activity, and the project/facility in total. ./ Modeling

- Air Quality ImpactAnalysis (AQIA) ./ ESA (Endangered Species Act) 

# .. ./ NHPA (NationalHistoric PreservationAct)



# •

# • E. TABLE OFESTIMATED EMISSIONS The following tables provide the total emissions in tons/year for all pollutants from the calculations required in Section D ofthis form, as appropriate for the use specified at the topofthe form. 

### E(i)

- Proposed New Facility



# • Pollutant PotentialEmissions (tpy) Proposed Allowable Emissions (tpy) PM

- Particulate Matter PM IO - Particulate Matter less than 10microns in size PM2.5

­ Particulate Matter less than 2.5 microns in size SOx

- Sulfur Oxides NOx

- Nitrogen Oxides CO

- Carbon Monoxide 

### voc- Volatile Organic Compound Pb

- Lead and lead compounds Fluorides

- Gaseous and particulates H2S0 4 - Sulfuric Acid Mist H

2S - Hydrogen Sulfide TRS

- Total Reduced Sulfur RSC

- Reduced Sulfur Compounds PM 

### 0.51 0.63 PM). 

### 0.51 0.63 PM 1.5 

### 0.51 0.63

SO. 

### 0.14 0.14 NO, 

### 31.40 34.06 CO 

### 63.06 77.56 VOC 

### 1448.50 76.21

Pb 

### Negligible Negligible Fluorides 

### Negligible Negligible

H2SO 4 

### Negligible Negligible H2S 

### Negligible Negligible TRS 

### Negligible Negligible RSC 

### Negligible Negligible Emissions calculations must include fugitive emissions ifthe source is one the following listed sources, pursuant to CAA Section 302(j): (a) Coal cleaningplants (with thermal dryers); (b) Kraft pulp mills; (c) Portland cementplants; (d) Primary zinc smelters; (e) Iron and steel mills; (i) Primary aluminum orereduction plants; (g) Primarycopper smelters; (h) Municipal incinerators capable ofcharging more than 250 tons ofrefuse per day; (i) Hydrofluoric, sulfuric, ornitric acid plants; (j) Petroleum refineries; (k) Lime plants; (I)Phosphaterock processingplants; (m) Coke oven batteries; (n) Sulfur recovery plants; (0) Carbon blackplants (furnace process); (P) Primary lead smelters; (q) Fuel conversion plants; (r) Sintering plants; (s) Secondary metal production plants; (t) Chemical processplants (u) Fossil-fuel boilers (or combination thereoi) totaling more than 250million British thermal units perhour heat input; (v) Petroleum storage and transfer units with atotal storage capacity exceeding 300,000barrels; (w) Taconite ore processing plants; (x) Glass fiber processing plants; (y) Charcoal production plants; (z) Fossil fuel-fired steam electric plants ofmore that 250 million British thermal units perhour heat input, and (aa) Any other stationary source category which, as of August 7, 1980, is being regulated under section III or 112 ofthe Act.



# •

# • E(ii)

- Proposed New Construction at an Existing Facility or Modification ofan Existing Facility This section ofthe application is not applicable. The application is for a new facility only. Pollutant Current Actual Emissions (tpy) Current Allowable Emissions (tpy) Post-Change Potential Emissions (tpy) Post-Change Allowable Emissions (tpy) PM 

### N/A N/A N/A N/A PM]1l 

### N/A N/A N/A N/A PM loS 

### N/A N/A N/A N/A

SO, 

### N/A N/A N/A N/A NO, 

### N/A N/A N/A N/A 

## eo N/A N/A N/A N/A 

## voe N/A N/A N/A N/A

Pb 

### N/A N/A N/A N/A NH3 

### N/A N/A N/A N/A Fluorides 

### N/A N/A N/A N/A

H2SO 4 

### N/A N/A N/A N/A H2S 

### N/A N/A N/A N/A TRS 

### N/A N/A N/A N/A 

## Rse N/A N/A N/A N/A 

# •

PM

- Particulate Matter PMIO - Particulate Matter less than 10 microns in size PM2.5 - Particulate Matter less than 2.5 micronsin size SOx

- Sulfur Oxides NOx

- Nitrogen Oxides CO

- Carbon Monoxide VOC

- Volatile Organic Compound Ph

- Lead and lead compounds NH3

- Ammonia Fluorides

- Gaseous andparticulates H2S04 - Sulfuric Acid Mist H2S - Hydrogen Sulfide TRS

- Total Reduced Sulfur RSC

- Reduced Sulfur Compounds 

# •

•

# • Instructions Use ofThisForm

• Proposed new construction or modifications should first be evaluated to determine ifthe change is majorunderthe major NSRprogram using the procedures at40 CFR 52.21 (Le., baseline actual to projected actual applicability test). 

### Ifthe proposed construction does not qualify as a major under that test, then it may be subject to the requirements ofthe minor NSRrule at 40 CFR49.151. 

### Helpful Definitions from the Federal MinorNSR Rule (40 CFR49)

- This is not a comprehensive list. 

# • 40 CFR 49.J 52(d)

- Modification means any physical oroperational change at a source that would cause anincrease in the allowable emissions ofthe affected emissionsunits for any regulated NSR pollutant orthat would cause the emission ofanyregulated NSRpollutant not previously emitted
. 

# • The following exemptions apply: (1) A physicalor operational change does not include routine maintenance, repair, orreplacement. (2) An increase in the hours ofoperation or in the productionrate is not considered anoperational change unless such increase is prohibited under any federally-enforceable permit conditionor otherpermit condition that is enforceable as a practical matter. (3) A change in ownership at a source is not considered a modification.

• 40 CFR 49.J52(d)

-Allowable emissions means "allowableemissions" as defined in §52.21(b)(16), except that the allowable emissions for any emissions unit are calculated considering any emission limitations that are enforceable as a practical matter onthe emissions unit's potential to emit.

• 52.21 (b)(16)

-Allowable emissions means the emissionsrate ofa stationary source calculated using the maximumrated capacityofthe source (unless the source is subject to federally enforceable limits which restrict the operating rate, orhours ofoperation, orboth) and the most stringent ofthe following: (i) The applicable standards as set forth in 40 CFR parts 60 and 61; (ii) The applicable State ImplementationPlan emissions limitation, including those with a future compliance date; or (iii) The emissions rate specified as a federally enforceable permit condition, including those with a future compliance date.

Page 7 of 15 

# •

# • A. General Facility Information 1. Company Name & Operator Name (ifdifferent): Provide the complete company and operator names. For corporations, include divisions or subsidiary name, ifany. 2. FacilityName: Provide the facility name. Please note that a facility is a site, place, location, etc... that may contain one or more air pollution emitting units. 3. Type ofOperation: Indicate the generally accepted name for the operation (i.e., asphalt plant, gas station, dry cleaner, sand & gravel mining, oil and gas wellsite, tankbattery, etc.). 4. Portable Source: Does the facility operate in more than one location? Some examples ofportable sources include asphalt batch plants and concrete batchplants. 5. Temporary Source: Atemporary source, in general, would have emissions that are expected last less than 2 years. Do you expect to cease operations within the next 2years? 

# • 6. NAICS Code: North American Industry Classification System. TheNAICS Code for your facility can be found at the following link 

### 7 North American Industry Classification System (http://www.census.gov/epcdinaics/nsic2ndx.htm#S 1). 7. SIC Code: Standard Industrial Classification Code. Although the new North AmericanIndustry Classification System(NAICS) has replaced the SIC codes, much ofthe Clean Air Act permittingprocesses continue to use these codes. The SIC Code for your facility can be found at the following link 

### 7 Standard Industrial Classification Code (http://www.osha.gov/pls/imis/sic manuaLhtml). 8. Physical Address: Provide the actual address ofwhere the facility is operating, not the mailing address. Include the State and the ZIP Code. 9. Reservation: Provide the name ofthe Indian reservation within which the facility is operating. 10. County: Provide the County within which the facility is operating. 11a & lIb. Latitude & Longitude: These are GPS (global positioning system) coordinates. This information canbe provided indecimal format or degree-minute-second format. 12a I2d. Section-Township-Range: Please provide these coordinates in 1/4 SectionlSection/TownshiplRange. (e.g., SW 1/4, NE 14 IS361T1ONIR21E). 

# •

Page 8 of 15 

# •

# • B. Current PermitInformation Provide a list ofall permits that have been issued to your facility. This should include any Federal MinorNew SourceReview (MNSR), Prevention ofSignificant Deterioration (PSD) orNonAttainment New Source Review (NA NSR) permits, in addition to the most recent Part 71 permit. The permit number must be included with each permit identified. 

## C. Contact Information Please provide the information requested in full. 1. Company Contact: List the full name (last, middle initial, first) ofthe owners ofthe facility orthe company contact. 

# • 2. OperatorContact: Provide the name ofthe operator ofthe facility ifit is different from the company contact. 3. Facility Contact: The facility contact must be the local contact authorizedto receive requests for data and information. 4. Compliance Contact: The compliance contact must be the local contact responsible for the facility's compliance withthis rule. Ifthis is the same as the Facility Contactplease note this on the form. 

## D. Attachments This section lists the information needed to complete the requested approval. This information should be accompanied by the supporting information listed on the form and described below. The information should be presented in enough detail to document how the facility is currently operating and/or how it is proposedto operate. ./ FORM SYNMIN Ifsynthetic minor limits are being requested, we recommend that the information from checklist tiled Form SYNMINbe included withthis application
. ./ Narrative description ofthe proposed production processes. 

# • 1. The narrative description should follow the flow ofthe process flow diagram to be submitted with this application. This needs to be as comprehensiveas possible tohelp in understanding the proposed facility andhow it will be operated. Forexample: What are the raw materials? What are the properties ofthe raw materials? 

### Does the productionprocess include heating, drying, the application ofchemicals, etc? How will the raw materials be affected by this process? What are the outputs from each step ofthe process (Le., crushed ore, dry gas, water, etc...)? Etc
.... 2. Theproposed operating schedulepresented interms ofhours perday, days per week, and weeks per year. 3. A list ofthetype and quantity offuels and/orraw materials used. Each fuel and raw material should be described in enough detail to indicate its basic chemical components. Page 9ofl5 

# •

# • ./ A process flow chart identifying all proposedprocessing, combustion, handling, storage, and emission control equipment (include the unit identification# or code). This flow chart should illustrate the detailed narrative description requested above
. ./ List and describe all proposed units, emission units and air pollution-generating activities. At a minimum, provide the following: 1. The hourly, daily and annual maximum operating rates for each operating unit, productionprocess, and activity. 2. The hourly, daily and annual maximum firing rates for each fuel and combustion equipment. 3. The capacity for storage units and the hourly, daily and annual maximum throughput ofmaterial in the storage units. 4. Material and product handling equipment and the hourly, daily and annual maximum throughput ofmaterial and product. 5. Tank designs, tank storage capacities, hourly, daily and annual maximum throughput ofmaterial and product. ./ Type andquantity offuels, including sulfurcontent offuels, proposed tobeused on a daily, annual and maximum hourly basis
. ./ Type and quantity ofraw materials used orfinal productproducedproposed to beused on a daily, annual and maximumhourly basis
. ./ Proposed operating schedule, including number ofhours perday, number ofdays per week and number of weeks peryear. 

### ./ A list and description ofall proposed emission controls, control efficiencies, emission limits, and monitoring for each emissionunit and airpollution generating activity. 1. Include manufacturer specifications and guarantees for each control device. 

# •

•

Page IOof15 

# •

# • Criteria Pollutant Emissions Estimates ./ Estimates ofCurrent Actual Emissions, Current Allowable Emissions, Post-Change Uncontrolled Emissions, and Post-Change Allowable Emissions for the following air pollutants: particulate matter, PMIO, PM2.5, sulfur oxides (SOx), nitrogen oxides (NOx), carbon monoxide (CO), volatile organic compound (VOC), lead (Pb) and lead compounds, ammonia (NH3), fluorides (gaseous and particulate), sulfuric acid mist (H2S04), hydrogen sulfide (H2S), totalreduced sulfur (TRS) and reduced sulfur compounds, including allcalculations for the estimates. 1. These estimates are to be made for each emissionunit, emission generating activity, in addition to total emissions. 

# • 2. The information should include all ofthe supporting calculations, assumptions and references. Emission estimates must address all emission units andpollutants proposed and/or affected bythe limitation and be presented in short term (e.g. pounds per hour) as well as annual (tons per year) units. 3. Any emission estimates submitted to the Regional Administratormust be verifiable using currently accepted engineering criteria. The following procedures are generally acceptable for estimating emissions from air pollution sources:

• Source-specific emission tests; • Mass balance calculations; • Published, verifiable emission factors that are applicable to the source. (i.e. manufacturer specifications) • Otherengineering calculations; or • Otherprocedures to estimate emissions specifically approved bythe Regional Administrator. 4. Guidance for estimating emissions canbe found at http://www.epa.gov/ttnichief/eipac/index.htmL Current Actual Emissions: Current actual emissions for a pollutant is expressed intpy and generally is calculated by mUltiplying the actual hourly emissions rate 

### in poundsperhour (lbs/hr) times actual hours operated (which is the number ofhours in a year) and dividing by 2,000 (which is the number ofpounds in a ton)
. 

# • 1. For an existing airpollution source (permitted and unpermitted) that operated prior to the application submittal, the current actual emissions are the actual rate ofemissions for the precedingcalendaryear and must becalculatedusing the actual operating hours, production rates, in-place control equipment, and types ofmaterials processed, stored, or combusted during the preceding calendar year. The emission estimates must be basedupon actual test data or, in the absence ofsuch data, upon procedures acceptable to the Regional Administrator. Current Allowable Emissions: Current allowable emissions for a pollutant is expressed in tpyand generally is calculated by multiplying the allowed hourly emissions rate in poundsper hour (lbs/hr) times allowed hours (which is the number ofhours in a year) and dividing by2,000 (which is the number ofpounds in a ton). 1. "Allowed" means the source is restricted bypermit conditions that limit its emissions and are enforceable as a practical matter (Le., allowable emissions). The allowable emissions for any Page 1\ of 15 

# •

# • emissions unit are calculated considering any emissions limitations that are enforceable as a practical matter on the unit's PTE. 2. For an existing permitted air pollution source that operated prior to the application submittal, the current allowable emissions arethe allowable rate ofemissions for the preceding calendaryear and must be calculated using the permitted operating hours, productionrates, in-place control equipment, and types ofmaterials processed, stored, orcombusted during thepreceding calendar year. 3. For an existing airpollution sourcethat does not have an established allowable emissions level prior to the modification must report thepre-changeuncontrolled emissions. Post-Change Potential Emissions (Potential uncontrolled emissions from proposed project): This is the maximum capacity ofa source to emit a pollutant under its physical and operational design. This is expressed in tpy and generally is calculatedby mUltiplying the maximum hourly emissions rateinpoundsper hour 

### (lbs/hr) times 8,760hours (which is the number ofhours in a year) and dividing by 2,000 (which is the number ofpounds in a ton). Post-Change AllowableEmissions: A source's allowable emissions for a pollutant is expressed in tpy and generally is calculatedby mUltiplying the allowed hourly emissions rate in pounds perhour (lbslhr) times allowed hours (which is the number ofhours in a year) and dividing by2,000 (which is the number ofpounds in a ton). 1. Unless the source is restrictedby permit conditions orotherrequirements that are enforceable as a practical matter, the post-change allowable emissions would be equivalent to post-change uncontrolled emissions. Forthe post-change allowable emissions a lower levelofallowable emissions may be proposed. 2. Forphysicaloroperational changes at minor sources and for minorphysical or operational changes at major sources, the total increase in allowable emissionsresulting from your proposed change would be the sumoffollowing:
• For each new emissions unit that is to beadded, the emissions increase would bethe potentialto emit ofeachunit. • Foreach emissions unit with anallowable emissions limit that is to bechanged or replaced, the emissions increase would be the allowable emissions ofthe emissions unit afterthe change orreplacement minus the allowable emissionspriorto the changeor replacement. However, this may notbe a negative value. Ifthe allowable emissions ofan emissions unit wouldbereduced as a result ofthe change orreplacement, use zero in the calculation. • Foreach unpermitted emissions unit (i.e., a unit without anyemissions limitations before the change) that is to be changed orreplaced, the emissions increase wouldbethe allowable emissions oftheunit after the change orreplacement minus thepotentialto emit priorto the change orreplacement. However, this may not be a negative value. Ifthe allowable emissions ofan emissions unit would be reduced as a result ofthe change or replacement, use zero in the calculation. 

# •

Page 12 of 15 

# •

# • ./ Modeling Analysis Do I need to do a modeling analysis? The Federal MinorNew Source Review Regulations at 40 CFR 49. 1 59(d)requires that a modeling analysis (AQIA) ofproposed emissions be performed ifthere is reason tobe concerned that new construction would cause or contribute to a National Ambient Air Quality Standard (NAAQS) or Prevention ofSignificant Deterioration (PSD) increment violation. In addition, ifthe AQIA reveals that the new constructioncould cause orcontribute to a NAAQS or PSD increment violation; such impacts must be reduced before a pre-constructionpermit can be issued. 

# • To facilitate the protection ofthe NAAQS and PSD Increment, EPA Region 8 requeststhatthose proposed activities that meet the following criteria perform an AQIA: I. The proposed activity has air emissions that EPARegion 8 determines have the potentialto cause adverse air quality effects for which an air quality impact analysis is necessary for an accurate assessment ofthe environmental impact ofthe activities proposed. 2. Modeling ofproposed emissions is usually warranted, even though the proposed activity does not meet the modelingrequirements, above, ifit is reasonable to believe the new activity may cause orcontribute to a violation ofapplicable ambient airquality standards orincrements in circumstances such as: (a) A substantialportion ofthe new ormodified emissions have poor dispersioncharacteristics (e.g., rain caps, horizontal stacks, fugitive releases, or 

### buildingdownwash) in close proximity to

### ambientair at the site boundary; (b) The new ormodified emissions are located in 

### complexterrain (e.g., terrain above stack height in close proximity tothe source); or (c) The new ormodified emissions are located in areas with existing air quality concerns. (d) 

### Ifyou have questions about whether modeling may be necessary based onthe 4th criteria above, please contact EPA Region 8'sModeling Lead: 

# • Gail Tonnesen Region 8 Modeling Lead Tonnesen.gai1@epa.gov 303-312- 6113

Page \3 of 15

# • What Kind ofAir Quality Modeling Analysis Is Needed? 1. EPA Region 8 considers a stepped orphased approach to modeling to be appropriate, as follows: Step I: Qualitative Air Quality Assessment Step2: Screening Modeling Analysis Step 3: PreliminaryModeling Analysis (refined modeling) Step4: Full Impact Modeling Analysis (refmed modeling) Step 5: PSD Increment and NAAQS Analysis Step 6: Additional Impact Analysis 2. Step 1: Qualitative Air Quality Assessment Narrative description ofthe current air qualityconditions andthe expected impactthepermitted source would have onthat air quality. Some suggested factors to consider in the qualitative discussioncould include meteorology, terrain, distance to ambient air, expected emissions, etc. Ifa convincing case cannot be made qualitativelythat no impacts to airquality would be expected, a screening analysis should next be performed. 3. Step

### 2: ScreeningAnalysis Forproposed new or modified sourcesthat meet the modeling requirement criteria identified above, protection ofair quality fromproposed emissions maybe shownby using a simple screening technique (e.g., SCREEN3 orAERSCREEN). Screening models are available for download at the EPA SCRAM website: http;//www.epa.gov/ttn/scramldispersionscreening.htm. A pre-approved modeling protocol is not necessaryprior to conducting a Screening Analysis. 4. Ifthe proposednew or modified emission increases do not increase ambient concentrations ofa pollutant by more than the significant impact levels, as compared to the SILs identifiedbelow, no further modeling is necessary. 

### S'

19ru 'fi



### leantI

### mpaet 

### Leves I

i 

# •



# •



# • Pollutant Averaging Period Class II Area SIL (uglm3) Class I Area SIL (ug/m3) i

S02 I hr 3 ppb or 7.8 ug/m' (interim) 

## ---­ 3 hr 25 1.0 24hr 5 0.2 Annual I 0.08 PM2 .5 24 hr 0.07 1.2 Annual 0.06 0.3 PM10 24hr 5 0.2 Annual I 0.08 N02 I hr 4 ppb or 7.5 ug/mj (interim) 

## ---­ Annual I 0.08 CO 1hr 2,000ppb 8hr 500ppb Note: The Class Iarea SILs areprovided as guidance and have not been formalized by EPA.

Page \4 of 15

# • 5. Sourcesthat cannot demonstrate protection ofair qualityusing a screening technique should continue to the modeling requirements in

### Step 3 through

### Step 6. Modeling in Steps 

### 3through 6 should be performed based an approved protocol. 6. Applicants are encouragedto contact the EPA Region 8 Modeling Lead priorto conducting any refmed modeling analysis (Step 3 through Step 6) to obtain anapproved protocol. 

### What ShouldI Include InMy Application If

### Modeling Is Necessary? I. Approved Modeling Protocol 

### In orderto expedite the permittingprocess, it 

### is recommended that you include a protocol that has already been approved. 

### An application will not be deemed complete until the protocol has been approved
. 

# • 2. Modeling Results In all cases, the modeling results should include the name ofthe model used, all input parameters, and the resulting output. Electronic copies ofthe modeling input/output files should beprovided to EPA Region 8 . 

### ./ ESA The Endangered Species Act requires us, in consultation withthe U.S. Fish and Wildlife Service andlorthe NOAA Fisheries Service, to ensure thatactions we authorize are not likely tojeopardizethe continued existence ofany listed species orresult in the destruction or adverse modification of designated critical habitat ofsuch species. To expedite the approval ofyour proposed construction, we encourage you to identify any listed species that you may bereadily aware ofthat couldbe affected byyour proposal. The following website has beenprovidedto assist you: http://www.fws.gov/endangeredl Simply enterthe Stateand County in which you proposeto constructto obtain a general listing
. 

# • ./ NHPA The National Historic Preservation Act requires us, in consultationwith State andlor Tribal Historic Preservation Officers to ensure that actions we authorize are not likely to affect culturalresources. To expedite the approval ofyourproposed construction, we encourage you to identify any cultural resources that you maybereadily aware ofthat could be affected by yourproposal. The following website has beenprovided to assist you: http://nrhp.focus.nps.gov/natreghome.do?searchtype=natreghorne Simply enterthe State and County in which you propose to constructto obtain a general listing.

Page 15 of15 

# •

# • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 8 AirProgram FEDERAL MINOR NEW SOURCE REVIEW PROGRAM IN INDIAN COUNTRY 

### Checklist

- Synthetic Minor LimitRequest (Form SYNMIN) Use ofthis information request form is voluntary and notyet approved by the Office ofManagement and Budget. The following is a check list ofthe type ofinfonnation that Region 8will use to process information on your proposedproject. While submittal ofthis form is not required, it does offer details on the information we will use to complete your requested approval and providing the information requested may help expeditethe process. Use ofapplication forms for this program is currently under Office ofManagement and Budget review and these information request forms will be replaced/updated after thatreview is completed. Please submitinformationto following two entities: The Tribal Environmental Contact for the specific reservation: 

# • Ifyou need assistance in identifying the appropriate Tribal Environmental Contact and address, pleasecontact the EPA Region 8 Tribal Air Coordinator: Alexis North, EPA Region 8 Tribal Air Coordinator 303-312-7005 north.alexis@epa.gov



# •



# • Company Name Dakota-3 E&P Company, LLC Facility Name Owl Comes Out 7-9H Pad CompanyContact or OwnerName loDellMizoue Title StaffEnvironmental Specialist Mailing Address 1001 17th Street, Suite 1200 Denver, CO 80202 Email Address loDell.Mizoue@Williams.com Telephone Number (303) 606-4056 FacsimileNumber (303) 692-8285



### Foreach criteria airpollutant,hazardous airpollutant and for all emission units and airpollutantgenerating activities to be covered by a limitation, include thefollowing: ./ Item 1 - Theproposedlimitation and a description ofits effect oncurrent actual, allowable andthe potential to emit. ./ Item2 - Theproposedtesting, monitoring, recordkeeping, andreporting requirements to beused to demonstrate and assure compliance with theproposed limitation
. ./ Item3 - A description ofestimatedefficiencyofairpollution control equipmentunder present or anticipated operating conditions, including documentation ofthe manufacturer specifications andguarantees. ./ Item4 - Estimates ofthe Post-Change Allowable Emissions that would result from compliance with theproposed limitation, including all calculations for the estimates
. ./ ItemS - Estimates ofthepotential emissions ofGreenhouseGas (GHG) pollutants before and after proposed emission controls. Federal MinorNSRPermit Coordinator U.S. EPA, Region 8 1595 Wynkoop Avenue, 8P-AR Denver, CO 80202-1129



### A. GENERAL INFORMATION

B. ATTACHMENTS

# • Instructions Use this form to provide general and summary information about the synthetic minor NSR source (facility orplant) on Tribal lands and to indicate the emissions limitations requested. Submit this form once, in addition to FORM NEW, for each synthetic minorNSR source on Tribal lands.
1. 

### Who Can RequestFederally-Enforceable Limitations Underthe Tribal NSR Authority? 

# • The Tribal NSR Rule applies onlyto sources located within the exterior boundaries ofan Indian reservation in the United States ofAmerica or other lands as specified in 40 CFRpart 49, collectively referred to as "Indiancountry". So, to use the authority in the Tribal NSRRule to create federallyenforceable limitations, a facility mustbe located within Indian country. Land ownership status (for example, whetherthe land is ownedbya Tribal member orwhetherthe land is owned in fee orintrust) does not affect how the rule applies. 

### 2. Who MightWantto Request Federally-Enforceable Limitations? The primary reason for requesting federally-enforceable limitations is to avoid an otherwise applicable federal CleanAirAct program, rule orrequirement. Many federal Clean Air Act programs use a source's "potential to emit" (PTE) air pollution to determine which rules orrequirements apply. A facility's PTE is based onthe maximum annual operational (production, throughput, etc) rate ofthe facility taking into consideration the capacity and configuration ofthe equipment and operations. Emission oroperational limits canalso betaken into consideration as maximums ifthey are federally enforceable. So, using a synthetic minor NSR permit to establish federally enforceable limitations can lower a facility's PTE and possibly allow the facilityto avoid certain federal CleanAir Act requirements. Three examples offederal Clean Air Act programs that use PTE to detennine whether theyapply are (I) the Prevention ofSignificant Deterioration (PSD) construction permittingprogram, (2) the Title V operating permit program, and (3) the Maximum Achievable ControlTechnology (MACT) program. For example, existing sources that are considered "major" for Title V (meaning theyhave the potential to emit airpollution at levels defmed in that rule as "major") must apply for a Title V operatingpermit. Ifa source accepts a federally-enforceable limitationthrough a synthetic minor NSRpermit that 

# • reduces their PTEto below the "major"threshold, and the source does not meet any ofthe other requirements that would trigger applicability to the part 71 program, thenthe source no longer needs a Title V operating permit. Whenplanning for the construction ofa new source or expansion ofan existing source, a source can also accept limitations onPTE (using a synthetic minorNSRpermit) that allow the sourceto avoid PSD. Limitations onPTE can similarlyhelp a source to avoid new MACT standards that would otherwise apply to the source. 

### 3. Section B. ATTACHMENTS This section lists the information that must be attachedtothe application fonn for each requested limitation. The requested limitation(s) must be described for each affected emissions unit (orpollutantgenerating activity) and pollutant and must be accompanied by the supporting information listed onthe form and describedbelow. Notethat applicability ofmany federal CleanAir Act requirements (such as Title V, PSD and MACT) is often based on facility-wide emission levels ofspecific pollutants. In that 

# • Page 2 of4

# • case, all emissions units at a facility and all pollutants regulatedby that given rule orregulation must be addressedby this section ofthe application form. 

### Item 1 - The requested limitation and its effect on actual emissions orpotential to emit must be presented in enough detail to document howthe limitation will limit the source's actual orpotential emissions as a legal and practical matter and, ifapplicable, will allow the sourceto avoid an otherwise applicable requirement. The information presented must clearly explain how the limitation affects each emissionunit and each airpollutant from that emissionunit. Use the informationprovided in response to Item4 below to explain howthe limitation affects emissions before and afterthe limitation is in effect. 

### Item 

### 2 - Foreachrequested limitation, the application must include proposed testing, monitoring, recordkeeping and reporting that will beused to demonstrate and assure compliance with the limitation. Testing approaches should incorporate and reference appropriate EPAreference methods where applicable. Monitoring should describe the emission, control orprocess parametersthat will be relied onand should address frequency, methods, and quality assurance. 

# • Item 3 - The application must include a description and estimated efficiency ofairpollutioncontrol equipment underpresent or anticipated operating conditions. Forcontrol equipment that is not proposed to be modified to meet the requested limit, simply notethat fact; however, for equipment that is proposed to be modified (e.g. improved efficiency) ornewly installedto meet the proposed limit, address both current and future descriptions and efficiencies. Include manufacturer specifications and guarantees for each control device. 

### Items 4

- Any emissionestimates submittedto the Regional Administratormust 

### be verifiable using currently accepted engineering criteria. The following procedures are generally acceptable for estimating emissions from air pollution sources: (i) Source-specific emissiontests; (ii) Mass balance calculations; (iii) Published, verifiable emission factors that areapplicable to the source. (ie.,manufacturer specifications). (iv) Other engineering calculations; or (v) Otherproceduresto estimate emissions specifically approvedby the Regional Administrator. Post-Change Allowable Emissions: A source's allowable emissions for a pollutant is expressed in tpy and generally is calculatedby multiplying the allowedhourly emissions rate inpounds perhour (lbs/hr) times allowed hours (which is the number ofhours in a year) and dividing by2,000 (which is 

# • the number ofpounds in a ton). 

### Item 5 - Newconstructionprojects that have thepotentialto emit GHG emissions ofat least 100,000 tpy C02 e and 100 or250tpy ona mass basis, modifications at existing PSD facilities that increase GHG emissions byat least 75,000tpy C02e and minor sourcesthat increase GHG emissions by at least 100,000tpy C02e and 100 or 250tpy on a mass basis are subject to PSD permitting requirements, even iftheydo not significantly increase emissions ofany otherpollutant. As such, anyrequested limits to avoid PSD must take into account greenhouse gases. Therefore, please include in yourpermit application estimates ofthepotentialemissions ofthe following pollutantsbefore and after proposed emission controls. More information about GHG permitting and how to calculate CO2 equivalents (C02 e), the mass emissions ofeach individual GHG

Page 3 of4 

# •

# • adjusted for its Global Warming Potential (GWP) can be found at: http://epa.gov/nsr/ghgdocs/ghgpermittingguidance.pdf 1. Carbon dioxide (C02) 

### 2. Methane (CH4) and its C02e 3. Nitrous oxide (N20)and its C02e 4. Hydrofluorocarbons (HFCs) and its C02e 5. Perfluorocarbons (PFCs) and its C02e 6. Sulfurhexafluoride (SF6) and its C02e


# •



# •

• Page4 of4i 

# •
OWL COMES OUT 7-9H PAD ATTACHMENTS:



# • Attachment A: Application Report Attachment B: Emission Inventory Attachment C: Flashing Emissions Calculations Attachment D: Representative Low Pressure Oil Analytical Data Attachment E: Representative Gas Analysis Attachment F: Engine Manufacturer's Specs Attachment G: Emission Control Device Manufacturer's Specs Attachment H: Process Flow Diagram of Facility Attachment I: Production Decline Curve Calculations Attachment

## J: Diesel Tank EPA TANKS 4.09d Emission Summary 

# I 

# I



# •

Dakota-3 E&PCompany. LLC. NSR Synthetic MinorApplication WEP211324 

# •

## ATTACHMENT A: APPLICATION REPORT 

# •



# •

•

Dakota-3 E&P Company, LLC. NSR Synthetic MinorApplication WEP211324

# •

• APPLICATION FORAN NSR PSD/TITLE V SYNTHETIC MINOR AIR QUALITYPERMIT

OWL COMES OUT 7-9H PAD OIL & GAS PRODUCTION FACILITY

J 

# I**~** f Prepared for: 

### Dakota-3 E&P Company, LLC 

## ! r 

### 1001 17th 

### Street, Suite 1200 ! 

### Denver, CO 80202 

## t I I 

## I 

# I I Preparedby: 

## t 

# I**~** 

### Bison Engineering, Inc. 1400 11th 

### Avenue I 

### Helena, MT 59601 f 

### (406) 442-5768 , i 

### www.bison-eng.com 

# • t

December 28, 2011 

# •

## TABLE OF 

## CONTENTS 

# •

, 

### 1.0 INTRODUCTION

.................................................................................................. 1 

# I 1
.1 Summary ................................................................................................... 1 

# I
, 

### 1.2 Site Location

.............................................................................................. 1 I 

### • I 1.3 Site Description

.......................................................................................... 1 

# i f 2.0 NARRATIVE DESCRiPTION

................................................................................3 3.0 POTENTIAL TO EMIT ESTIMATE

.......................................................................5 

# I 3.1 Production Storage Tank VOC Emissions

................................................. 8 3.2 Produced Casing Head Gas Emissions

..................................................... 8 

# • 3.3 Reciprocating Internal Combustion or Compression Ignition Engines

....... 9 3.4 Natural Gas External Combustion Unit Emissions

.....................................9 3.5 Truck Loading Emissions

...........................................................................9 3.6 Fugitive Emissions: Dust and Equipment Leaks

.......................................9 4.0 EMISSIONS AND OPERATIONAL LIMITS REQUESTS

................................... 10 4.1 Production Storage Tank Emissions

........................................................ 10 4.2 Reciprocating Internal Combustion or Compression Ignition Engines

..... 10 5.0 ALLOWABLE EMISSIONS

................................................................................. 11 5.1 Storage Tank Emissions

.......................................................................... 11 5.2 Produced Casing Head Gas Emissions

................................................... 11 5.3 Rice Engine Emissions

............................................................................ 11 5.4 Natural Gas External Combustion Unit Emissions

................................... 11 5.5 Truck Loading Emissions

......................................................................... 12 5.6 Fugitive Emissions: Dust and Equipment Leaks

..................................... 12 5.7 Diesel Storage Tank Emissions

............................................................... 12 6.0 PROPOSED MONITORING AND RECORDKEEPING

...................................... 13 6.1 Production Storage Tanks

....................................................................... 13 6.2 Production Storage Tank Emissions Control Device

............................... 14 6.3 Produced Casing Head Gas Emergency Utility Flare

.............................. 16 6.4 Rice Engines

............................................................................................ 17 6.5 Natural Gas-Fired External Combustion Units

......................................... 17 6.6 Truck Loading

.......................................................................................... 18 6.7 Fugitive Emissions: Dust and Equipment Leaks

..................................... 18 6.8 General Recordkeeping Requirements

....................................................20 7.0 QUALITATIVE AIR QUALITY ASSESSMENT

....................................................21 8.0 ENDANGERED SPECIES ACT

..........................................................................22 9.0 NATIONAL HISTORIC PRESERVATION ACT

..................................................23

Owl Comes 7-9H Pad 12/28111 pg. ii NSR Synthetio Minor Permit Application Project#: WEP211324 

# •

## FIGURES Figure 1: Example of Maximum PTE from a Seven Well Pad

................................... 6 Figure 2: Example ofActual Production from a Seven Well Pad

.............................. 7 

## ATTACHMENTS Attachment A: Attachment B: Attachment C: Attachment D: Attachment E: Attachment F: Attachment G: Attachment H: Attachment I: Attachment 

### J: Application Report Emission Inventory Spreadsheets E&P Tank V2 Emission Summary Output Representative Low Pressure Oil Analytical Data Representative Gas Analysis Engine Manufacturer's Specs Emission Control Device Manufacturer's Specs Process Flow Diagram of Facility Production Decline Curve Calculations Diesel Tank EPATANKS 4.09d Emissions Summary

Owl Comes Out 7-9H Pad 12128111 pg. iii NSR Synthetic Minor Permit Application Project#: WEP211324 

# •

## 1.0 INTRODUCTION 

# •

1.1. Summary Dakota-3 E&P Company, LLC (Dakota-3) is submitting this application for a Prevention of Significant Deterioration (PSD) and/or Part 71 Title V (Title V) synthetic minor permit to the Environmental Protection Agency (Agency) in accordance with the Federal Minor New Source Review (NSR) Rule (40 CFR 49) adopted pursuant to the Federal Clean Air Act. 

# • Dakota-3 is proposing to construct and operate the Owl Comes Out 7-9H Pad Oil and Gas (O&G) production facility on the FBIR. Included in this application for a synthetic minor permit are allowable emissions specified by requested federally enforceable permit conditions that limit the emissions from the facility to below the PSD and/or Title V major source thresholds. These limits can be found in Section 4.0 ofthe application. 

### 1.2. Site Location The Owl Comes Out 7-9H Pad is proposed to be located in the northwest % of the southwest % Section 17, Township 150 North, Range 91 West, Mountrail County, on the FBIR in North Dakota. 

### 1.3. Site Description At the proposed Owl Comes Out 7-9H Pad there will be six oil and gas wells that are proposed to produce to the facility. The facility will be situated on an approximately ten acre site, with an elevation of approximately 2,000 feet (mean sea level), in Mountrail County, North Dakota. The surrounding area is mainly used for agriculture and livestock grazing. The proposed pad's associated well names are: 1. Owl Comes Out 7-9HA 2. Owl Comes Out 7-9HB 3. Owl Comes Out 7-9HD 

# • 4. Owl Comes Out 7-9HX 5. Owl Comes Out 7-9HY 6. Owl Comes Out 7-9HZ The names of the wells may be subject to change due to landowner requirements, drilling location changes, timing of well leases, etc. The Agency will be notified if the names change.

Owl Comes Out 7-9H Pad 12128/11 pg.1 NSR SynthetiC Minor Permit Application Project#: WEP211324 

# •

## 2.0 NARRATIVE DESCRIPTION This section of the application provides a detailed description of the operations at the Owl Comes Out 7-9H Pad. For purposes of estimating emissions from this facility, the combined first twelve-month potential production from the six proposed wells at this facility was used. These production rates can be found in Attachment B, Emission Inventory. The production rates used in this application are grossly overestimated when compared to the actual predicted production rates in the first and subsequent years. The wells that will be producing to this facility do not begin producing at the same time. In reality, there will be up to six or more years' difference inwhen the initial production from wells begin to when the final wells are constructed and begin to produce. It is not physically possible for all of the wells to be simultaneously drilled and begin initial production. However, to allow for reasonable flexibility and to be conservative, this application has considered a maximum potential production case from the pad. Due to ever-changing drilling schedules, completion schedules, economics, etc., the wells will begin actual production at different times. The entire pad facility will consist of the following primary production equipment and capabilities. 6 - Heater Treater/Separators 6 -line-Heaters (0.75 MMBtu/hr max) 30 - Oil Production Tanks 1 - Gasoline Recycling Pump 12 - Produced Water Tanks 6 - Electric Lifting Units 6 - Oil and Gas Producing Wells 1 - Truck Loading Rack 1 - Manufactured Produced Gas Flare 6 - Diesel Engines 1 - Manufactured Enclosed Tank Vapor Combustor 

### The oil/gas/water emulsion being produced from the wells is transported up each weIIbore using an electric lifting unit. The emulsion from the wells producing to this site is transported in a closed system to individual two-phased separators and then to the three-phase separators (heater treaters). The initial two-phase separator reduces the pressure of the oil/gas/water emulsion to allow the gas to separate from the oil and water. The heater treaters then reduce the pressure closer to ambient pressure and heat the leftover emulsion using a flame-arrested line-heater. The combination of higher temperatures and low pressures allow for additional separation of the gas/oil/water phases from each other because ofdifferences in densities. The line-heater is fueled by onsite produced casing head gas that is routed to the heater's combustion chamber. Propane may also be used as an alternative fuel if necessary. Following the heater treater the oil and water are routed to their separate storage tanks. The produced casing head gas is transferred from the two-phase separators to the sales gas pipeline. An onsite utility flare serves as an emergency backup in the event that the gas cannot be placed into the sales line. The oil and water production tank's working, standing, breathing, and flashing vapors are routed to an enclosed combustion Owl Comes Out 7-9H Pad 12/28/11 pg.2 NSR Synthetic Minor Permit Application Project#: WEP211324 

# •

### device. The stored oil is transported for sale via the truck loadout. Produced water is stored in the onsite water storage tank until it is transported otfsite using the water pipeline. At the facility, there is a small gasoline fueled pump located near the production storage tanks. This pump is commonly known as a "transfer" or "recycle." The pump is used to periodically recyde the liquids (oil/water) in the bottom of the production tanks back into the heater treater for further separation. Otherwise, the facility is completely electrified; however, the electricity lines have not yet been installed at the facility. Onsite diesel genset engines will provide electricity until transmission lines are installed. A process flow diagram and plot plan ofthe site is shown in Attachment H. 

# •

•

•

Owl Comes Out 7 -9H Pad 12/28/11 pg. 3 NSR Synthetic Minor Permit Application Project#: WEP211324 

# •

## 3.0 POTENTIAL

## TO EMIT ESTIMATE In estimating the average production for the first twelve months, a decline curve was developed. The decline curve takes into account the fact that the initial production ofthe well will greatly decline over the initial twelve months of production. Assuming that each well's production would be equivalent to the initial production will grossly overestimate production and is not realistic for how an oil and gas well operates. The decline curve calculated for this facility was developed using existing well data from wells previously drilled and producing in the same region. The confidential decline curve estimations are included in Attachment I of the application. As noted in Section 2.0 above, determination of potential emissions from the proposed facility has been approached in a very conservative fashion. The combined production 

# • rate for the pad assumes all of the wells start production simultaneously (represented in example Figure 1). With this assumption, the initial 30-day production from each well is summed to estimate a potential total production rate from the pad. Operating practice is that the wells will be drilled over time, often months or even years apart. Further, after each well is drilled and brought into production, the initial production rate generally decreases greatly before the next well is drilled. Therefore, this potential to emit (PTE) estimate is meant only to define an outer envelope of emissions for permitting applicability purposes. Furthermore, the allowable emissions estimates presented in Section 4 are also very conservative compared to anticipated actual emissions that could be emitted at the facility during any given 12-month rOiling average. An example demonstrating the predicted production of a theoretical multiple well pad over an extended period of time is presented in Figure 2. This example does not represent predicted production from the well pad being permitted in this application; however, it does serve to demonstrate typical operations for this type offacility.



# ..



# • Owl Comes Out 7-9H Pad 12/28/11 pg.4 NSR Synthetic Minor Permit Application Project#: WEP211324

# • • 

# •

------- 

# •

Figure 1: Example ofMaximum PTE from a SevenWell Pad 

# Example of Maximum PTE from a Seven Well Pad 6,000
• All seven wells begin

### ~ production 5,000 simultaneously·

-000
. 

# S' 

# •
CD 

# + 

# 1000.. • c'**~** • Total Production from seven 

# i • Wells on Pad



# -**--~~~-**

# ~.ooo ......



# ...

# ~.~.~.~.~.!.!.!.!.~.~.~.~ --­ ............. 1,000

-­



## o o 10 20 30 40 Month

Owl Comes Out 7-9H Pad 12128111 pg.5 NSR Synthetic Minor Permit Application Project #: WEP211324

# • • • Figure 2: Example ofActual Production from a Seven Well Pad 

## Example ofActual Production From a Seven-Well Well Pad 3,500 

## It' 6th and 7thwells beg1n production

--'-Total Production from Sellen Wells on Pad 12-Month Rolling Average Oil Production -12-Month RollingAverage Oil Production Limit



### o o 5 10 15 20 25 30 35 40 Month 3,000

2,500
Q**~** 5th well begins production 

## 51

., 2,000 

### I' 

# J i/: -S 1,500 c 

### j 1,000 2nd well begi ns production 1st well begins production 500

Owl Comes Out 7-9H Pad 12128111 pg.6 NSR Synthetic Minor Permit Application Project #: WEP211324 

# "

# •
Potential emissions from this facility originate primarily from the heater treater lineheaters emissions, the production storage tank uncontrolled emissions, truck loading emissions, diesel genset emissions, and fugitive emissions (e.g., truck loading, equipment leaks and road dust). The maximum design capacity of the engines and natural gas-fired external combustion units, in conjunction with maximum annual anticipated oil and gas production rates of this facility, were used in determining the facility's potential to emit (PTE). The oil, gas, and water production rates were estimated by using data from recently drilled wells in the same region and extrapolating the rates for this proposed pad. 

# • The potential emissions are stated in the Application for New Construction (Form NEW), Table E(i)
- Proposed New Facility. The emissions from the facility fall into the following categories (Le., emitting units). 1. Production Storage Tanks (Oil and Water); 2. Casing Head Gas (Produced Gas); 3. Reciprocating Internal Combustion Engines (Recycle Pump Engine and Diesel Gensets) 4. Natural Gas External Combustion Units (Heater Treater Line-Heaters); 5. Truck Loading 6. Miscellaneous Fugitive Emissions (Fugitives); 

### 3.1 Production Storage TankVOC Emissions To estimate the uncontrolled PTE of the production tank's vapors (working, breathing, standing, and flashing), extended BTEX low pressure oil analyses were taken from representative wells producing out of the same geological region. E&P Tanks V2 was used to calculate the production tank's vapors using the anticipated maximum production rates, area-specific ambient pressure/temperature data, representative process operating conditions, and sampled analytical data. The E&P Tanks output summary includes all of the needed input data in the emission inventory, such as the vapor rate that is produced from the tanks (scf/bbl), the rnol% ofthe vapor components, such as VOCs, HAPs, GHGs, etc. 

# • All applicable uncontrolled emissions from the storage tanks calculations, low pressure analytical data, and E&P TANKS program inputs and outputs are provided in the attachments. 

### 3.2 Produced CasingHead Gas Emissions At the two-phase separator, +90% of all of the initial casing head gas is separated and sent to the gas sales pipeline. After the initial separation occurs, the leftover emulsified oil/gas/water is transferred to the three-phase heater treater. The heater treater then separates the residual gas from the oil and water. Due to the reduced pressure of the heater treater, the sales pipeline pressure is too high to overcome; therefore, the residual gas is routed to the onsite utility flare. Furthermore, if the gas sales pipeline Owl Comes Out 7-9H Pad 12/28/11 pg. 7 NSR Synthetic Minor PermitApplication Project #: WEP211324 

# •

# •

pressure increases to the point at which the produced casing head gas from the twophased separator cannot be sold or the gas pipeline has a malfunction, the flare serves as an emergency backup. 

### 3.3 ReciprocatingInternalCombustion or Compression Ignition Engines Diesel engines connected to generators provide the facility with electricity. The potential emissions from the engines are estimated by assuming the engine is operating 8,760 hours per year and applying the federally required 40 CFR 63 Subpart JJJJ or 40 CFR 60 Subparts "" and ZZZZ emission limits as applicable. 

### 3.4 Natural Gas External Combustion Unit Emissions The natural gas external combustion units at the facility are the heater treater line­ 

# • heaters. Each heater is rated to a maximum capacity of 750,000 Btulhr. The emissions are based on AP-42 factors and assume the heater is running 8,760 hours per year. 

### 3.5 TruckLoadingEmissions Oil sales and water pipelines are planned for this facility in the future; however, since the pipeline infrastructure has not yet been constructed, the facility is not anticipated to be hooked to the oil sales pipeline in the nearfuture, and the produced oil and water will be trucked from the facility. The emissions associated with the truck loading operations will be estimated using daily production, AP-42 factors, and submerged fill loading without any control. 

### 3.6 Fugitive Emissions: Dust and EquipmentLeaks Fugitive emissions from equipment leaks and dust are not required to be estimated for purposes of potential to emit within the NSR permitting program. However, the fugitive emissions will be estimated after a final permit is issued and production begins in order to track to the twelve-month rolling average actual emissions. The fugitive leak emissions primarily consist of leaks from connectors, open-ended lines, valves, pumps, etc. These emissions will be estimated using EPA's average emissions factors for total hydrocarbon emissions from O&G production operations. The fugitive dust emissions 

# • will be estimated using AP-42 factors to capture the emissions associated with vehicle traffic at the location.



# • Owl Comes Out 7-9H Pad 12/28/11 pg. 8 NSR Synthetic Minor Permit Application Project #: WEP211324

# •
4.0 EMISSIONSAND OPERATIONALLIMITS REQUESTS Datoka-3 is requesting emissions and operational limits at the Tracy 15H Pad in order to obtain a synthetic minor status with regard to the NSR permitting programs. The federally enforceable permit conditions will allow Dakota-3 to operate the facility while emitting less than the PSDfTitie V major source thresholds of250/100 

### tons peryear of a regulated criteria pollutant, 10 tons per year of an individual HAP, and 25 tons per year of all emitted HAPs. 

### 4.1 Production Storage TankEmissions 

# • The majority of emissions associated with the facility occur from the working, breathing, standing, and flashing vapors from the production storage tanks. Therefore, Dakota-3 will control the storage tank VOC and HAP emissions by installing an enclosed smokeless combustion device that has been independently tested and certified to exceed the requirements of 40 CFR 60.18 at 98% destruction efficiency (ORE). Although this control device is certified to meet 99% ORE. Oakota-3 will assume the minimum required 98% ORE for purposes of calculating the controlled tank vapor emissions. This control device will allow Oakota-3 to apply a 98% control efficiency to the uncontrolled PTE. On this basis, the requested emission limit from the storage tanks is: 28.01 tons peryear ofVOCs and 0.26 tons per year of HAPs. 

### 4.2 Reciprocating Internal Combustion or CompressionIgnition Engines Oakota-3 will be required to limit the emissions from any reciprocating intemal combustion or compression ignition engine being operated at the facility due to the federally enforceable requirements of 40 CFR 63 Subpart 

### JJJJ or 40 CFR 60 Subparts 1111 and 

# zzzz., as applicable. 

# •

Owl Comes Out 7-9H Pad 12/28111 pg. NSR Synthetic Minor Permit Application Project #: WEP211324 

# •

## 5.0 ALLOWABLE EMISSIONS 

# •

The allowable emissions are the new estimated controlled potential to emit based on the federally enforceable controls and limits requested in Section 

### 4. The allowable emissions are also presented in the Application for New Construction (Form NEW), Table E(i)
- Proposed New Facility. 

### 5.1 Storage TankEmissions The storage tank controlled emissions are estimated by applying 98% control efficiency to the uncontrolled VOC, HAP, and CH4 emissions. Although the VOC, HAP, and CH4 emissions are reduced by the smokeless combustion device, CO, NOx • PM, PM1Q, PM2.5 

# • and N20 emissions are created by the combustion process. These emissions estimates are calculated using AP-42 factors and applying the weight percentages of the criteria pollutant and greenhouse gas components from a representative gas analysis. 

### 5.2 Produced Casing Head Gas Emissions As stated in Section 3, the produced casing head gas is transferred to the gas sales pipeline. However, the residual gas released from the oil/gas/water emulsion in the heater treater will be sent to the onsite utility flare. Furthermore, ifthe gas sales pipeline pressure increases to the point at which the produced casing head gas from the twophased separator cannot be sold or the gas pipeline has a malfunction, the flare serves as an emergency backup. No limits have been requested for the produced casing head gas emissions at the facility; therefore, the emissions estimate is equal to the potential to emit. 

### 5.3 RICE Engine Emissions No limits have been requested for the RICE at the facility. Dakota-3 is required to meet the federally enforceable emission standards depending on the size (hp) and date of manufacture; therefore. the emissions estimate is equal to the uncontrolled potential to emit. 

# • 5.4 Natural Gas External Combustion Unit Emissions No limits have been requested for the natural gas external combustion units (0.5-0.75 MMBtu/hr heater treater line-heaters) at the facility; therefore, the emissions estimate is equal to the uncontrolled potential to emit.



# • Owl Comes Out 7-9H Pad 12/28/11 pg. 10 NSR Synthetic Minor Permit Application Project#: WEP211324

# •
5.5 TruckLoadingEmissions No limits have been requested for the truck loading operations at the facility; therefore, the emissions estimate is equal to the uncontrolled potential to emit. 

### 5.6 Fugitive Emissions: Dust and EquipmentLeaks


# • Fugitive emissions from equipment leaks and dust are not required to be estimated for purposes of potential to emit within the NSR permitting program. However, the fugitive emissions will be estimated after a final permit is issued in order to track the twelve· month rolling average actual emissions. The fugitive leak emissions primarily consist of leaks from connectors, open-ended lines, valves, pumps, etc. These emissions will be estimated using EPA's average emissions factors for total hydrocarbon emissions from O&G production operations. The fugitive dust emissions will be estimated using AP-42 factors to capture the emissions associated with vehicle traffic on the location. 

### 5.7 Diesel Storage TankEmissions There will be an onsite storage tank at this facility to store diesel fuel that will be utilized in the diesel gensets. This tank will be either a horizontal or vertical 1,000 gallon tank. Emissions for this tank were estimated using EPA TANKS 4.09d and determined to be less than 0.01 tpy. Because of the low level of emissions from this equipment, it has been determined to have insignificant emissions. The EPA TANKS 4.09d emissions summary output is in Attachment 

### J.



# •

Owl Comes Out 7-9H Pad pg. NSR Synthetic Minor Pennit Application Project #: WEP211324 

# •

## 6.0 PROPOSED MONITORINGAND RECORDKEEPING 

# •

As per the Application for Synthetic Minor Limit Request (Form SYNMIN). Page 1 (B). ATTACHMENTS, Item, 2, Datoka-3 is required to propose testing, monitoring. recordkeeping, and reporting requirements that will be used to demonstrate and assure compliance with the proposed allowable emissions. 

### 6.1 Production Storage Tanks The production storage tanks will have their flashing and standing/working/breathing vapors routed by a closed-vent system to equipment designed to capture the VOC and total HAP emissions generated at the facility for sale or other beneficial purposes, or an emissions control device that achieves a minimum of 98% destruction efficiency. 

# • Dakota-3 will follow the tank manufacturer's recommended maintenance schedule and procedures to ensure optimum performance. Furthermore, Dakota-3 will employ the following methods to ensure the tank vapors are efficiently being routed to the requested proposed device(s): a. Thief hatch covers will be weighted and properly seated; b. Pressure relief valves (PRV) will be set to release at a pressure that will ensure flashing, and standing/workinglbreathing losses are routed through a closed-vent system to equipment designed to capture the VOC and total HAP vapors. The vapors will be routed to equipment designed for sale or other beneficial purpose, or an emissions control device; and c. Periodic measurements of the peak pressure and vacuum values in the vapor recovery and control systems will be conducted to ensure that the pressure and vacuum relief set-points are not being exceeded (e.g., due to fouling or increased activity levels) resulting in venting and possible damage to equipment. 

### Monitoring Requirements: Dakota-3 will estimate the emissions from the production storage tanks by performing one ofthe following methods:
a. Direct measurement of standing/working/breathing losses by sampling and lab 

# • analysis; b. EPA TANKS 4.0.9d to calculate standing/working/breathing losses; c. Direct measurement offlashing emissions by sampling and lab analysis; d. Process simulator such as PROMAX, HYSIM, HSYS using site-specific sampling and lab analysis to calculate flashing emissions in conjunction with EPA TANKS 4.0.9d to calculate standing/working/breathing losses; e. API E&P TANKS Software V2.0 using representative sampling and lab analysis to calculate standing/working/breathing losses and flashing emissions; or f. Other methods approved by EPA.


# • Owl Comes Out 7-9H Pad 12/28/11 pg. 12 NSR Synthetic Minor Permit Application Project #: WEP211324

# • Recordkeeping Requirements: In order to demonstrate compliance with the 12-month rolling emission limits for the oil production tanks, Dakota-3 will track facility oil production rates for each month, beginning with the first full calendar month after operations commenced. The monthly totals will be summed to create a production rate for the prior twelve month rolling operating period. As demonstrated in Attachment C of this application, the total 

## voe, total HAP, and any single HAP emissions in tons per year are directly proportional to the production rate of oil at the facility. Based upon this relationship, compliance with the requested limits in this application will have been maintained if the production rate during any twelve month rolling period is less than the production rate used to establish the emission limits. 

# • Dakota-3 will keep records of all input parameters and calculations, including the input and output reports for the models, used to determine the monthly emissions. 

## 6.2 Production Storage TankEmissions ControlDevice The limits requested on the emissions from the storage tanks are directly dependent on the production throughput in the tanks. All emissions at the facility will be controlled in one or more enclosed combustors and/or utility flares that are designed and operated to reduce the mass content of

## voe (or

## voe and HAP) emissions in the vapors vented to the device by at least 98%. 

### Dakota-3 will follow, for each enclosed combustion device and utility flare, the manufacturer's written operating instructions, procedures and maintenance schedule to ensure good air pollution control practices for minimizing emissions. All vent lines, connections, fittings, valves, relief valves, or any other appurtenance employed to contain and collect vapors and transport them to the enclosed combustor, or utility flare will be maintained and operated during any time the facility is operating. Each enclosed combustion device will be: 

# • a. Designed to have sufficient capacity to achieve at least a 98% 

### destruction efficiency for hydrocarbon volumetric flow and BTU content routed to the device; b. Operated with a liquid knock-out system to condense any condensable vapors; c. Equipped with a thermocouple to detect the presence of a pilot flame with a minimum accuracy of ±2 percent of the temperature being monitored expressed in 

### °e, or ±2.5 

### °e; d. Equipped with a recording device, such as a chart recorder or similar device, to document the presence ofa flame; e. Equipped with an electronically controlled ignition system with a malfunction alarm and remote notification system ifthe pilot 'name fails; f. Maintained in a leak-free condition; and g. Operated in a smokeless mode. Owl Comes Out 7·9H Pad 12/28111 pg.13 NSR SynthetiC Minor Permit Application Project#: WEP211324 

# •

# •
Monitoring Requirements: 

### Dakota-3 will identify, via an independent engineering analysis or a manufacturer or vendor guarantee, each control device's operating parameters within which they will meet the 98.0% reduction requirement. Dakota-3 will monitor the control device operations to confirm proper operation as follows: a. Monitor the pilot flame using a thermocouple and a chart recorder that indicates the continuous ignition ofthe pilot flame; b. An inspection of the chart recorder to ensure proper operation will be done whenever an operator is on site; at a minimum, quarterly; c. A visual inspection of the pilot flame to ensure proper operation will be done whenever an operator is on site; at a minimum, quarterly; • d. Measure one other parameter determined during the independent engineering analysis or provide a manufacturer orvendor guarantee; and e. Visually confirm that no smoke is present during operation of any enclosed combustor or utility flare whenever an operator is on site; at a minimum, quarterly. Recordkeeping Requirements: 

### a. Records will be kept ofthe site-specific design input parameters provided for the independent engineering analysis or provided to the manufacturer or vendor and used to properly size the enclosed combustors and utility flares to assure the 98% reduction requirements. b. Records will be kept ofall required monitoring ofthe control device operations. c. Records will be kept of any instances in which any control device was bypassed or down in each calendar month, the reason for each inCident, its duration, and the corrective actions taken orthe preventative measures adopted to avoid such bypasses ordowntimes. d. Records will be kept of the any exceedance of the operating parameters specified in the manufacturer or vendor guarantee or engineering analysis and selected for the required monitoring. The records will include the enclosed combustor's total operating time during the calendar month in which the • exceedance occurred, the date, time and length oftime that the parameters were exceeded, and the corrective actions taken or the preventative measures adopted to operate the facility within that operating parameter. e. Records will be kept ofany instances in which the pilot flame is not present in the enclosed combustor or the utility flare, the date and times that the pilot was not present and the corrective actions taken orthe preventative measures adopted to increase the operating time ofthe pilot flame. f. Records will be kept of any instances in which the thermocouple (or other heat sensing monitoring device) installed to detect the presence of a flame in the enclosed combustor or utility flare is not operational, the time period during which it was not operational, and the corrective measures taken. 

# • Owl Comes Out 7-9H Pad 12/28/11 pg. 14 NSR Synthetic Minor Permit Application Project#: WEP211324

# •
g. Records will be kept of any time periods in which visible emissions are observed emanating from an enclosed combustor or utility flare. h. Records will be kept of all required testing and monitoring. The records will include the following: i. Date, place, and time of observations, sampling or measurements; ii. Date(s) analyses were performed; iii. Companies or entities that performed observations and the analyses; iv. Analytical techniques or methods used; v. Results of such analyses or measurements; and vi. Operating conditions as existing at the time of sampling or measurement. 

# • i. Monitor the pilot flame using a thermocouple, and/or a chart recorder or other means that indicates the continuous ignition ofthe pilotflame; 

### j. A check of the chart recorder or other monitoring device to ensure proper operation will be done whenever an operator is on site; at a minimum, quarterly; k. A check of the pilot flame to ensure proper operation will be done whenever an operator is on site; at a minimum, quarterly; 

### I. Measure one other parameter determined during the independent engineering analysis or provide a manufacturer orvendor guarantee; and m. Visually confirm that no smoke is present during operation of any enclosed combustor or utility flare whenever an operator is on site; at a minimum, quarterly. Dakota-3 will follow, for each enclosed combustion device and utility flare, the manufacturer's written operating instructions. procedures and maintenance schedule to ensure good air pollution control practices for minimizing emissions. 

## 6.3 Produced Casing HeadGas Emergency Utility Flare Dakota-3 is not requesting any limits from the produced casing head gas because it is being sent to the gas sales pipeline. If a malfunction from the pipeline occurs and the gas cannot be sold, Dakota-3 will record the volume ofgas sent to the emergency utility • flare. During an emergency or malfunction Dakota-3 will route the produced casing head gas to the onsite utility flare that will be designed and operated to reduce the mass content of 

## voe (or 

## voe and HAP) emissions in the vapors vented to the device by at least 98%. Dakota-3 will follow, for the utility flare, the manufacturer's written operating instructions, procedures and maintenance schedule to ensure good air pollution control practices for minimizing emissions. All vent lines, connections, fittings, valves, relief valves, or any other appurtenance employed to contain and collect vapors and transport them to the utility flare will be maintained and operated during any time the facility is operating. Owl Comes Out 7-9H Pad 12/28/11 pg.15 NSR Synthetic Minor Permit Application Project#: WEP211324 

# •

# •

The emergency utility flare will be:
a. Designed and operated in accordance with the requirements of 40 CFR 60.18 and 40 CFR 63.11. b. Designed to have sufficient capacity to achieve at least a 98% destruction efficiency for hydrocarbon volumetric flow and BTU content routed to the device; c. Operated with a liquid knock-out system to condense any condensable vapors; d. Equipped with a thermocouple to detect the presence of a pilot flame with a minimum accuracy of ±2 

### percent of the temperature being monitored expressed in 

### DC, or±2.5 

### DC; e. Equipped with a recording device, such as a chart recorder or similar device, to document the presence ofa flame; f. Equipped with an electronically controlled ignition system with a malfunction • alarm and remote notification system ifthe pilot flame fails; g. Maintained in a leak-free condition; and h. Operated in a smokeless mode. 

### Monitoring Requirements: The monitoring requirements for the emergency utility flare will be the same as described above for the production storage tanks control device as specified in Section 

### 6.2. Recordkeeping Requirements: The recordkeeping requirements for the emergency utility flare will be the same as described above for the production storage tanks control device as specified in Section 

### 6.2. 

## 6.4 RICE Engines Depending on the size (hp) and date of manufacture, Dakota-3 is required to meet the emission standards set forth in 40 CFR 63 Subpart 

### JJJJ or 40 CFR 60 Subparts 

### 1111 and ZZZ2, 

### as applicable. Dakota-3 will properly operate and maintain the engines as per the manufacturer's specifications to ensure compliance with the above standards. If the engines emissions are not certified to meet the required standards, Dakota-3 will have performance tests conducted on the engines as required by the applicable subparts. 

## 6.5 Natural Gas-FiredExternalCombustion Units Due to the insignificant emissions associated with the 0.5 to 0.75 MMBtu/hr natural gas (or propane) fired line-heaters, no monitoring or recordkeeping requirements are being proposed by Dakota-3. 

# • Owl Comes Out 7-9H Pad 12/28/11 pg. 16 NSR Synthetic Minor Permit Application Project#: WEP211324

## 6.6 TruckLoading 

# •

The truck loading rack is designed for submerged filling of the tank trucks. This is standard operating procedure. Monitoring Requirements: The monitoring requirements for truck loading will be estimating the monthly VOC, total HAP, and any single HAP emissions from the loadout operations using input parameters, equations, and emission factors from AP-42, Fifth Edition, Volume I, Chapter 5. Recordkeeping Requirements: 

# • Total VOC, total HAP, and any single HAP emissions, in tons, from loading operations will be calculated and recorded at the end of each month, beginning with the first full calendar month after operations commenced. Prior to twelve full months of operation, Dakota-3 will, at the end of each month, add the emissions for that month to the calculated emissions for all previous months since operations commenced, where applicable, and record the total. Thereafter, Dakota-3 will, at the end of each month, add the emissions for that month to the calculated emissions for the preceding eleven months and record a newtwelve-month total. Dakota-3 will keep all input parameters and calculations used to determine the monthly emissions. 

## 6.7 FugitiveEmissions: EquipmentLeaks Dakota-3 will minimize leaks of volatile organics from each piece of equipment in hydrocarbon service at this facility. Work Practice and Operational Requirements: a. At a minimum, Dakota-3 will detect and repair leaks at each tank thief hatch, 

# • centrifugal compressor vent, reCiprocating compressor vent, instrument, meter, diaphragm, pressure relief device, dump arm, open-ended valve or line, vent line, flange, connection, fitting, or any other appurtenance employed to contain and collect vapors and transport them. b. Dakota-3 will make the first attempt to repair any leaking equipment within five days afterthe leak is detected. c. Any leaking eqUipment will be repaired as soon as practicable, but no later than 15 days after the leak is initially detected, unless the repair is technically infeasible without a facility shutdown. Such equipment will be repaired before the end of the first facility shutdown, after the leak is initially detected. Dakota-3 will make the first attempt to repair any leaking equipment within five days after the Owl Comes Out 7-9H Pad 12/28/11 pg. 17 NSR Synthetic Minor Permit Application Project#: WEP211324 

# •

# •
leak is detected. Dakota-3 will minimize leaks of volatile organics from each piece ofequipment in hydrocarbon service at this facility. Monitoring Requirements:
a. Dakota-3 will conduct leak detection monitoring on a semi-annual basis. If no instrument reading of 10,000 ppm or greater is measured for two consecutive semi-annual monitoring periods, the required monitoring frequency will change from semi-annual to annual. If any single instrument reading of 10,000 ppm or greater is measured, the required monitoring frequency will change back to semi­ annual. b. Dakota-3 will use one of the following methods to conduct leak detection of the equipment: 

### i. Method 21 • a) Use the equipment leak detection methods in 40 CFR Part 60, Appendix A-7, Method 21; and b) If an instrument reading of 10.000 ppm or greater is measured. a leak is detected. ii. Optical Gas Imaging Instrument a) Use an optical gas imaging instrument for equipment leak detection in accordance with 40 CFR Part 60, Subpart A, §60.18(i)(1) and (2) ofthe Alternative workpractice formonitoring equipmentleaks; 

### b) Any emissions detected by the optical gas imaging instrument are a leak unless screened with Method 21 (40 CFR Part 60, Appendix A-7) monitoring, in which case 10,000 ppm orgreater is designated a leak; c) The optical gas image will include an image of the equipment in addition to any observed leaks; and d) The optical gas imaging instrument will be operated in accordance with the instrument manufacturer's operating parameters. iii. Operator Developed Inspection Protocol - Best Management Practices a) Develop and use a written inspection protocol approved by EPA, based on best management practices, for leak detection; b) Any emissions detected by the protocol are a leak unless screened with Method 21 (40 CFR Part 60, Appendix A-7) monitoring, in which case 10,000 ppm orgreater is designated a leak; • c) The protocol will include the following: I. A detailed description of the best management practice to be used for leak detection; II. A requirement to use a log book that contains a list, summary description, or diagram showing the location of all equipment in hydrocarbon service at the facility, and the required recordkeeping for equipment leaks; and III. A requirement that the log book be signed by the inspector at the completion ofeach inspection.


# • Owl Comes Out 7-9H Pad 12/28/11 pg.18 NSR Synthetic Minor Permit Application Project#: WEP211324

# • Recordkeeping Requirements:
a. Dakota-3 will document and maintain a record of each leak detection inspection and repairs. b. All leak detection inspection records will include, at a minimum, the following information: i. Date ofthe inspection; ii. All documentation and/or images produced in the inspection; 

### iii. Findings ofthe inspection; iv. Any corrective action taken; and v. Inspector's name and signature. 

## 6.8 General Recordkeeping Requirements 

# • Total VOC (orVOC, total HAP, and any single HAP) emissions, in tons, from each piece of equipment will be calculated and recorded at the end of each month, beginning with the first full calendar month after operations commenced. Prior to twelve full months of operation, Dakota-3 will, at the end of each month, add the emissions for that month to the calculated emissions for all previous months since operations commenced, where applicable, and record the total. Thereafter, Dakota-3 will, at the end of each month, add the emissions for that month to the calculated emissions for the preceding eleven months and record a new twelve-month total. Dakota-3, when feasible, may use a Supervisory Control and Data Acquisition (SCADA) system to monitor and record the needed data. SCADA consists of computer systems that monitor and control industrial, infrastructure, or facility-based processes. The system may include, but is not limited to, production monitoring, electronic pressure indicating transmitters, pilot flame status monitoring, valve position setpoints, temperature monitoring, alarm notification, data logging, flowmeter monitoring, etc.


# •

Owl Comes Out 7-9H Pad 1 pg. NSR Synthetic Minor Permit Application Project#: WEP211324 

# •

# • 7.0 QUALITATIVE AIR QUALITYASSESSMENT The climatology and air quality of the area of interest is dominated by continental air masses with only minor terrain features (from a synoptic point of view) of interest. The area has excellent ventilation since large air mass movement is not limited by any significant geologic features. This is in stark contrast to other areas in Region 8 that may have limited atmospheric mixing due to mountain valleys or large mountain ranges that can minimize the effect ofair mass movement. Ambient air quality data has been gathered in and near the reservation for many years. The results of that ambient monitoring network indicate ambient concentrations of all pollutants well below the National Ambient Air Quality Standards (40 CFR 50). Those measured values include the impact of substantial oil and gas development that has • occurred in the region including development nearthe proposed facility. In fact, much of the monitoring data yields background values despite the presence of current industrial activity and general anthropogenic sources. The reported data shows that the values are the same or nearly the same as one would find in a rural location devoid of any industrial activity (although industrial activity is clearly nearby). A typical facility's actual emissions are modest in nature (Le., below typical permitting thresholds) as demonstrated in Figure 2: therefore, additional ambient impact analysis is not warranted.

Owl 7-9H Pad 12/28/11 pg.20 NSR Synthetic Minor Permit Application Project #: WEP211324

## 8.0 ENDANGERED SPECIESACT 

# •

•



# • The Endangered Species Act (ESA) requires EPA, in consultation with the U.S. Fish and Wildlife Service (USFWS) and/or the NOAA Fisheries Service, to ensure that actions EPA authorizes are not likely to jeopardize the continued existence of any listed threatened or endangered species (TES) or result in the destruction or adverse modification of designated critical habitat of such species. TES are considered to be those species recognized by the USFWS as listed or proposed species, and those designated as candidate TES under the ESA. Whether critical habitat for TES exists near the facility will first be assessed by consulting the USFWS North Dakota Ecological Service Field Office website (http://www.fws.gov/northdakotafieldoffice/index.htm) and noting the potential occurrence of each TES by county. Once the potential presence of a species is assessed, a look at whether any critical habitat exists in the vicinity of the facility will help detennine the possibility of any impacts from the facility on TES. EPA will conduct an evaluation of the potential for TES impacts from the facility and consult, as appropriate, with USFWS regarding identification and mitigation ofany impacts

.

Owl Comes Out 7-9H Pad 12/28/11 pg.21 NSR Synthetic Minor Permit Application Project #: WEP211324 

# •

## 9.0 NATIONAL HISTORIC PRESERVATION ACT 

# •

• The National Historic Preservation Act requires EPA, in consultation with State and/or Tribal Historic Preservation Officers, to ensure that actions authorized are not likely to affect cultural resources. The potential for cultural resources in the vicinity of the facility will be assessed by consulting with the North Dakota State Historic Preservation Office (NDSHPO) and the Tribal Historic Preservation Officer(s), and conducting a literature review of available information from the area immediately surrounding the facility (http://history.nd.gov/hp/siclass1.html). If the review finds a need for more intensive analysis ofthe immediate area ofthe facility, a Class II or III cultural resources inventory may be performed as required. EPA will conduct the consultation with NDSHPO and Tribal officials to identify any cultural resources that could be impacted by the facility and any needed mitigation measures for those impacts.

Comes 7-9H Pad 12/28/11 pg.22 NSR Synthetic Minor Permit Application Project#: WEP211324 

### I

# •

ATTACHMENT B: EMISSION INVENTORY



# •

•

Cakota-3 E&P Company, LLC. NSR Synthetic MinorApplication WEP211324 

# •

# • • •

__ 

# •

Dal<ota-3 

# E!P**Com~an~,** 

# LLC

Facllfty Infonnatlon Owl Com
.... Out7·6H Pad InputData GREEN· Requlrealnput RED • No Input required. This Is a calculated value. AssociatedWells: Owl Come
.. Out7·6HO, 7·9HY. 7.9HB, 7.9HX. 7·9HA. 7· 4HZ Not Producing Yet 

### 0:
....._ ......... --...­

# ~**h~_** IPI'OdUCUOn DatI on BOPD 4268 

# In...,. of

.. ...,do!r(IIOPOl, bIIOII0
.... P

.........thllO.,.oflII1ICIucIton. Mscfd 2966 

# .,_In lIIcf...,do!r,
...... on'"
..........thlJO.,. of

.............. 

# " 

# .... Decline Factor 0.505**~dIdInoltclorlorthtthl"..,of""""".** Blood on"'-...-uo" lII1ICIuclng_lIItht_1IoId

...._. Adjusted BOPD 2157 Tllio 10tht

......... SOPO
...........10be pIOducod

..lngtht

___NIl
..... fIotor. Adjusted Produced Gas (MIcfd) 1499 Tllio 10tht

............. ofl1li
...... 10 IIlIJIII'1IIdtoIIfII'II- _Ing

...__ ............ fIotor. OlllCondensate Tlnk Date Deacrlptlon Flash Gas Method: Process Simulator u.. thtdrop down_10 "'- tht

...""'rIIIt

....hIlllIIIIIIIod. Process Simulator Estimated acflbbl 41.57 TheocfJllblhmdI

__unolllllltor"""'-_10. Bloodon "'

__ EIP T
..kEmil
..... SummIryouq,ut. Estimated Tank Vapors (1Cfdl 89650.71 Tllio IothtlItknIIIdocfdoflonk_

...... o.tht

......Ing:.....,IIOPD IIIIIIIpIIodby'" ocfIbbl_on U
.... Lower Heating Value 2395.38
......., huIIftg

.....(IIb.I/IctIoflonhopo

.... Blood o. ""'_EIP T.,kEmlllioftIlwnInooy Clu4!HJI. MolecularWeight 41.99 Moloculon
..1ghI ., ....kYIIpO'"In
...........,pound-moIo(IbIIIHno1oj. Blood an..."..- EIP T
..kEmIllIoft Sum""'YOutput. VOC% 76.568 VOC
....htfnooIIon oftht !ankYIIpO'l1li(C3+/. Blood•• ""'_EIPTlllkEmlllionSUm_IVouq,ut. VOC TPYIBOPD Emlulon Factor 0.649 Blood

... ElPT.,tEmlllIoftSum_Clu4!HJI.{Su_OUlputc_.H_roIootIoftlhlp TPYand SOPO, HAP% 0.718**~Wllightfnoollon** .,1Io.kYllpO'
.... Bloodon ..."..- EIPT

..kEmlllion su_Clu4!HJI. HAP TPYIBOPD Emission Factor 0.006 Bloodon ............".ElPT
... EmIII

....SU_Clu4!HJI.(SU_Output_••

__hIp TPY.1Id IIOPIll C02% 0.23%**~Wllightfnoollon** ofthttlllk

............ Blood on............".EIP TankEmIlI
....s

__Output. CH4% 1.59%**~Wllightfnoollon**

## 01110.'
........l1li. Blood

.. ....-_EIPT.,kEmlll
....SUm_ouq,ut.**H~_ight%** 0.16% WIIight..-of

.................. Bloodon..."..- EIP T

..kEmIoaIon S
....1IIOf)'Clu4!HJI. H

2SmoIe% 0.20% molopo_oftht.k

........ l1li. Blood

.. ..."..-EIPT'.'EmlillonSum_'YClu4!HJI. Enclosed Smokeless Combustor ,*thtdropdown

..lIUto"'-tht

.................Ion
.......**~.** Control Destruction Efficiency 98% 01
......... Tllio 1I.1Ind "'rbllOllo
..........**~-,"-~_~_i~~~~0~*_'·,I:.,.;,.',,"'~"'*_1I~<'¥'~f!ill'.,._l@rill'!.,'1I"'~,,"%'_"'~** "'

...**-~--~~-,.** ..**~,."7""'''".** ?,' }Ii**~\"'A_f\~_o/** I

...**\~~r..-'** 

# I

# • • • 

# • Dakota-3 E&P Company, llC Input Data GREEN

### =Requires input FIICIIIly Information Owl Comes Out 7·6H Pad Associated Wells; Owl Comes Out 7.6HO. 7·9HY. 7·9HB. 7.9HX. 7·9HA, 7· 4HZ RED· No input required. This is a calaJlated value. 

# L

..._ ............ Treater Gas Data DeacrlDtJon Btu/set 1814.20 

# ""*' oIWIIoINn
... (F
..... ",,_1IoId0II1111tt11a' MolllCUlarWeight 31.69**~",.,...""'locuIorwolghtof"'''''''''OIIIn''''''''''''(F** ..... ",,_1IoId 0111IIIIIIytts, Specific Gravity 1.09 _'Y

.._."""

....gmtf¥lD..........,"""""....., ...IIjIOCIIIcgmtf¥of
... ....-.. ... (F

...m""
..._floIdon-!!loll, (f

.....__**1IoId0ll~'** Averege MolecularWeight 31.69 VOe% 50.99% rmcwolghtlrlldlon01
..............0II1Noet:WIfahI'lI. natMolll'l). (FIO
.. ..-- floId OIl
......) HAP% 0.72% woIghtlrIIdIon of
................. (Noll:WoIgId, natMolll'l). (F

....._ ..... 1IoId011
......1 0.770% woIghtIrIIdIon01
...WIIoINn011. (Noll:WeIght'IIo. natMoII'IIo). (F
..... ",,_1IoIdOII-¥tll, CH4% C02% 21.422%**~woIghtlrlldlonof"'WIIoINnOll'** (NoII:WoIgld,natMolll'l), IFrom",,_IIoIdOll.....,.II, H:!S weight % 0.000% WIIgIIt pon:ont01
...WIIoINn011. (F",
....p_1IoId 011 .....,.11, H:zS mole % 0.000%**~1II01o_1II01"''''''''''''** ... (F..,..
..p-ftolol

........!!IoIo' Connected to sales line 

### u........ down
................... opproprllloomlolloftCOIIIIOItype. ControIICapture Efficiency 100"""
........."
.......__ 100%
.........of
... lfllond,COIIIIOIoIIIcllncy"'''''oppIIcoblo

## co""''''

## (coIIIb-. pltlln, utilityflo.., .110). Treater Bumer(a) DeacrlDtlon Total Btulhr 4500000 olllbu
........."'r
...h
......_burI1tI(.,lnbIuIhr. 1f

....... muIIIpItburnt". tdd

........ hIotlnput

.......r, Hours ofOperation 8.760 "-'Io11ollN

........."

.........,,1Uhouro ""_, Truck Loading Deacrlptlon Ollis hauled bytruck

...........down
......to ..........._l'ODrIIIo011
....._.110110toIoIltnuah,!.ACT no Inputvoluoo
.. .-.InIdInLIntI 300035. Submerged loading: dedicated normal service 0.6 

## ..........._lilt"'

........... appIOIIItoIt

.... oIoperollon.The
...........n**""*,,wII~** beotIoc:WbOMdon ....01 ope_n, 41.99 MoIIeulo,WIIgIIt01tonkvapollin
........10.Anllltlld

_ moloculorwoIghI_ tIoohIng omlllllo••from ""_ElPTift.dtto, MolectJlarWeight VaporPreasure 2.30 rutvaporD_of

..uId Ioedod, pou.. ""
......Inch

......1uIolPtlajllno
....pecII!cdtto10 IMIIIobIt,

... _to rlblo2on TlUcklolding lib, Temperature 50.00 • ..,- ofbulkIquIdIo.IcIod InF
.......... llllno
....pecII!cdill

.......... _onto1hMtld

............IIInptratUre. Load Rate (bbllhr) 180 Lood

.... '"IquIdIo.IcIod I.bomNI ",,_. Load Time (hrs) 1.00 Tho

....

## It"''''''''
.......utonolHll**(hnI~** 

### IP
....umaticpump. and Contollere (None) IGlycol Dehydrator(None)

# • • 

# • •

FIICHIIy:

IComesOut7.eH Pad 

# Dakota-3 E&P Com

""I.tadwen.: Com

..Out 7-6HO. 7 • •7.gHB.7-9HX. 7·9KA. 7· 14HZ 

### Emission Summary

HAP NOlI PM PM10 PM2.S 13.01 NIA NIA N/A N/A 0.40 3.37 0.21 0.21 0.21 0.04 1.93 0.15 0.15 0.15 1.02E·01 26.09 0.15 0.15 0.15

0.17 N/A NIA N/A N/A Neali!:Jible N/A N/A N/A N/A

NlA NIA NIA NlA N/A N/A N/A N/A NIA N/A N/A N/A N/A NlA NlA

HAP 0.26 0.40 0.04 1.02E·01

0.17 Negliaible

NlA NlA N/A S02 N/A 0.00 0.01 1.24E·01

N/A NIA NlA NlA NlA Oil/CondensateTanks Casino Head Gas Treater Burner RICE Engine Truck Loadina Fuel Storage Tank Pneumatic Pumo Pneumatic Controllers Glycol Oehydrator 'Total.(!PYJ

OillCondensateTanks Casina Head Gas Treater Burner RICE Enoine Truck Loading Fuel Storage Tank Pneumalic Pump Pneumatic Controllers GlYCOl Dehvdrator ITotal.**!TP~** 

### I ,



## I I YOC 1400.29 23.32 0.11 6.80 17.97 NaaliQible

NIA N/A N/A 1448.50 

# "

voc 28.01 23.32 0.11 6.80 17.97 Nealiaible

N/A N/A N/A 76.21 I I Uncontrolled Potential to Emit Criteria Pollutants CO H2 S N/A N/A 18.36 NA 1.62 NlA 43.08 N/A N/A NlA NlA NlA N/A N/A N/A N/A NlA N/A 13.72 

### II 31.40 

### I I 0.51 

### I I 0.51 

### I I 0.51 

### II 63.06 

### II 0.00 

### I I Allowable Potential to Emit Criteria PollutantsNOx PM PM10 PM2.5 CO H2S 2.67 0.12 0.12 0.12 14.50 N/A 3.37 0.21 0.21 0.21 18.36 0.00 1.93 0.15 0.15 0.15 1.62 N/A 26.09 0.15 0.15 0.15 43.08 N/A NlA N/A N/A N/A N/A NIA N/A NIA NlA N/A NIA NlA N/A NIA NlA NIA N/A N/A NIA N/A NIA N/A N/A N/A N/A N/A N/A N/A N/A N/A 0.97 I I 34.06 I I 0.63 

## I I 0.63 

## I I 0.63 

## II n.S6 

## II 0.00 

## I I Emissions of lead and lead compounds. ftumides. sulfuric acid mist. total raducad suWur. and reduced sulfur compounds are assumed to be negitigable for upstream oil & gas operati,,". on the FBIR. HCHO Negligible

0.00 Negligible

0.10 Nealiaible

NIA Nealiaible NeQligible Negligible 0.14 

### I , 0.10 

### I

S02 HCHO N/A Nealiaible 0.00 0.00 0.Q1 Nealiaible 1.24E-01 0.10

N/A Nealiaible N/A NIA NIA Negligible N/A Nealiaible N/A Negligible 0.14 

## I I 0.10 

## I

!I\!II._,_

.. _ __**1"Y"\"'JI'r1rl>''''''i''';~''''-:--~¥><'~~_'''''''''1'f»'''''''''~~** __**'''_''_<W>Mi'!''''''''''''''~_''''''''"'''''''-~'<l~~** ....**t...-:>~** ....."''''_'''''''''

__**-'''r~1')\"f-q'~~'~.",'''~_'~** ... 

## ....... .......**~$.~:_''',~'!.''I** __**':"I'~·~·'·'''''~--'---~~'''W-"'':'''~'!''_.''~'-''''_'''''~'~~''''''''''~~** __**'''~~''''''''''''0!.~r<** __**''''''''7:'''''7''~~._'''**

# • • • • 

# I

Coakota-3 E&P

# Compan~, LLC

# II
Facility: OwICo
.....0ut7.eH Pad Asooclat.dW&II.: Owl CoI'II

..0ut7-6HD. 7. 9HY. 7·9HB. 7·9HlC. 7-9HA, 7· 4HZ

Potential To Emit Actual Greenhouse Gasesb Greenhouse Gasesb

OiVCondensate Tanks Caslna Head Gas Treater Burner RICE Engine Truck loadina Fuel Storage Tank Pneumatic Pump Pneumatic Controllers Glvcol Dehvdrator CO2 N/A 3299.80 2318.82 2.27E+02

0.05 NlA N/A N/A N/A CH. 28.84 9.80 0.13 0.34 0.37 N/A NlA N/A N/A N20 N/A 0.00 0.03 0.07 N/A NfA N/A N/A N/A CO2 1967.53 3299.80 2318.82 2.27E+02

0.05 NlA NlA N/A N/A CH. 0.00 9.80 0.13 0.34 0.37 NfA NlA NlA N/A NP 0.04 0.00 0.03 0.07 N/A N/A N/A N/A NIA ITotals (TPY) 5845.77 39.49 0.10 7813.30 10.65 0.14 

### I 

### I I 

## II I I I I
GHG Ma

.. Emiatllons (tpy): 5885.36 GHG ManEmlnlons (IllY): 7824.09 C02&(tpyl: 6705.50 co:z. (IllY): 8079.06 ApplicabletotheTailoring Rule?: No Hydronuorocarbons (HFC.).

__rbollS (PFC.). and Sulfur H••anuorid

.. (SF6) "",1asIons are not created from 0&0productionoperaHons

.

# • • • 

# •

Flare GasVolume! 89.651 scf/day 

### Tanks

Oil Production!:!'!'" BOPO

Lower Heating Value! 2395.38 Btu/scf

MolecularWeight! 41.99 Ibllb-mole! VOC wt Fraction! 76.57% VOC Emission Factor! 0.649 tprlbopd I HAPs: Benzenewt Fraction Toluene wt Fraction E-Senzenewt Frectiion Xylene wt Fraction n-Hexane wt Fraction 0.0166% 0.0132% 0.0018% 0.0109% 0.6143% I I I I 2.2.4-Trimethylpentaner--::-=::=::-...., wt Fraction! 0.0587% 

# Dakota-3 E&P Company, LLC
Owl Comes Out 7-6H Pad Associated Wells: Owl Comes Out 7-6HD. 7-9HY. 7-9HB. 7-9HX. 7-9HA. 7-4HZ

Controlled emissions all! calculated based on a**~destruction** effICiencyoftheVOC gas. HAP Emission Factor! 0.006 tfIYfb()t?Ol C02wt Fraction! 0.23% CH4 wt Fraction! 1.59%**~'·-?,f"_""''''''~'''_",~l'''~~t\l~_'''-"''r'"'J'~~'':''''** __**'''''''~~*-''~~~~'~'"''_'~~_~~~~!4.+*I'~~** ___**''--'_''''''"~_~'~'''''~~~~''!'!'''~~f!'''''i!'''''~:.'IR'''':'!~_~~~~~''''~~'"I!.''''~~''''~'"**

# • • Oakota-3 E&P Company, LLC
Owl Comes Out 7-6H Pad Associated Wells: Owl Comes Out 7-6HO. 7-9HY. 7-9HB. 7-9HX. 7-9HA. 704HZ 

## [**hn~** CRITERIA POLLUTANT EMISSIONSa Uncontrolled VOCs (PTE): Using E&PTanks Run: 

### I 0.649 TPV VOCIBOPO 1 Controlled VOCs (Allowable): sing E&PTanks Run: 

### I 0.649 TPVVOCIBOPO 1 x

x 

### I 2156.62 BOPO

12156.62 BOPO x

x 

### I
I ORE 0%

ORE 98% 1 1400• 29

28.01 TPvl

TPVI Uncontrolled HAPs (PTE): Using E&PTanks Run: Benzene E-Benzene

Toluene n·Hexane

Xylene 2.2.4-Trirnelhylpentane 3,735 scflhr 3,735 scflhr 3.735 scflhr 3.735 scflhr 3.135 scflhr 3,135 scflhr x x x x x x 1/379scfIlb-mole 1/379scfllb-mole 11379 scfllb-mole 11379 scfllb-mole 1/379scfIIb-mole 11379 scfllb-mole x x x x x x 41.99 IMb-mol 41.99 1Mb-mol 41.99 1Mb-mol 41.99 Ibllb·moI 41.99 Ibllb-moI 41.99 1Mb-mol x x x x x x**~**

### ~**~ ~** **~**

### ~**~** x x x x x x ORE 0% 0% 0% 0% 0% 0% 

# .. = =



# .. = = 0.081b1hr 0.01 Iblhr 0.051blhr 2.54lb1hr 0.051blhr 0.241b1hr Uncontrolled TOTAL HAPS (TPV) TPY 0.34


# .. = 0.03 0.24 

### = 11.14 

### = = 0.20


# .. 1.06



# .. 13.01 

## I Controlled HAPs (Allowable): Benzene E·Benzene

Toluene n-Hexane

Xylene 2.2.4-Trimethylpentane



# • 3.135 scflhr 3.735 scflhr 3,735 scflhr 3.735 scflhr 3.735 scflhr 3.735 scflhr 1/379scfllb-mole 1/379scfllb-mole 1/379scfIIb-mole 1/379scfl1b-mole 1/379scfllb-mole 1/379scfllb-mole x**~** x x 41.99 IMb-mol 41.99 1Mb-mol 41.99 1Mb-mol 41.99 IMb-mol 41.99 1Mb-mol 41.99 IMb-mol 1 0

.02% x x x**~** x x x**~** x x x**~** x x x**~** x x x**~**



# • 98% 98% 98% 98% 98% 98% 0.01 x O.OOlblhr O.OOlblhr O.OOlblhr 0.051blhr 0.00 Iblhr 0.00 Iblhr 

### • 

### = 0.00 x 

### = 

# .. = 0.00 x 

### = 0.22 x 

### = = ,. 

# .. 0.00 x 

# .. .. 0.02 I x 0.26 ControlledTOTAL HAPS (TPy) 

# ..

# • • 

# • •


# r Dakota-3 E&P Company, LLC
Owl Comes Out 7·6H Pad Associated Wells: Owl Comes Out 7·6HO. 7-9HY. 7·9HB. 7·9HX. 7-9HA. 704HZ 

### Tanks
Uncontrolled NOx:
NOX:' 0 scflhr x 

### I 2,395 Blu/scf

### I

0.00 Iblhr x

x 1MMBtu/I,OOO,OOO Btu
8760 hrl;c: x 

## I x 

### I 0.068 IblMMBtu 

### I

1tonl2OOO Ib 0.00
0.00 Iblhr 

### I 

### TPYI NOx Created byCombustion (Actual)
MOx:1 3,735 scflhr x 

## I 2,395 Blu'scf

### I x 1MMBtu/1.000,OOO Btu x 

### I 0.068 IblMMBtu 

### I 0.81 Iblhr

### I

0.61 Iblhr x 8760 hrl;c: x 

## I 1tonl2ooo Ib 2.87 

### TPYI Uncontrolled PM: 

### PM:I 0 scflhr 

### I x 

### I 7.8 

### I 0.00 Ib11,ooo.000 scf
Iblhr 

### I x 

### I I 

# .
8760 hr!:t!: 

### I 

### I 0.00

x Iblhr 

### I 

### I 1tonl2OOO Ib 

### I 

# .. I 0.00 

### TPY 

### I PM Created byCombustion (Actual) 

### PM:I 3,735 scflhr 

### I x 

### I 7.6 

### I 0.03 Ibl1.000,ooo scI
Iblhr 

### I x 

### I I 

## ..
8760 hr!:t!: 

### I I 0.03

x Iblhr 

### I 

### I 1tonl2ooo Ib 

### I 

# .. I 0.12 

### TPV 

## I**1"';'''':~\''''''V-'~'''1'<'''''''!r'''''~'-'''''''''>i'''l':>jM;W'I'!IiY~1r_",¥~~,,,,,,,,:c'''<J'''')''j1'!'"''';f_*l~~""'1-** __**"""''''·.I''~:''''~'Y'''I'I'''~''''''"_''"'~'·'~''''''\li,,_,~,''_~~J))l['''~-""'""{-~"'~'''''-''':<\',~,.'''''I~~~'''''~'';''"-~~~~'''''"''''''''I~''''''!"''':J''''''''''''~:'P'''<ft'~:'''~""":r,.'t"'"~'''~'''1!'Y\')''** __**'''~~to1li'''I«1;(1':''~,M!'>''''''''~~(>'**

# • • • • I Oakota-3 E&P Company, LLC
Owl Comes Out 7-6H Pad Associated Wells: Owl Comes Out 7·6HD. 7-9HY. 7-9HB. 7-9HX. 7·9HA. 704HZ

Uncontrolled CO:
co:j 0 sdlhr x ! 2,395
0.00 Blulsd!
Iblhr x

x 1 MMBIul1.000.000 Blu
8760**hr/~** x 

## I X j 0.370 IblMMBtu 

### I

1 tonI2000 Ib 0.00
0.00 Iblhr

### I

TPY 

## I

CO Created byCombustion (Actual)

co:! 3,735 scflhr x 

## I 2,395**~~1** Blulscfl
Iblhr x

x 1 MMBI

....1.000.000 Btu
8760**~r/yr** x ! x 

## I 0.370 IbIMMBIu 

### I

1t0ni2000 ILl 3.31 

### I 14.50 Iblhr

### I

TPY 

### I
aNOl<. 502. and CO emission factors are from AP-42 Table 13.5-1 (Emission Factors for Flare Operations)

. 

### Tanks 

# I

# This section ofthe document has been redacted because it contains copyrighted information. The redacted information canbe viewed from the hard copy ofthe docket, which is available at the EPA Region 8 Office upon request.