# •

APPLICATION FOR PSD/TITLE V SYNTHE**~MIjNffj~-:­** 

# AIRQUALITYPERMIT

NORTH SEGMENT6-7H PAD OIL & 

# GAS**;~i_ODUCTI** 

# FA**~'--"f\~~:'f ~;-~,** **-/-.;:~_** :'­ ':;'"



### 1400 11thAvenue

--­ 

# --­


# -­



# -**~-­** 

### BisonEngineering, Inc.

# •**~~©~~~~~** [;EC 28 

## 2011 

# 8P-AR Decembel' 28,2011 DAKOTA-J E&PCOMPANY, LLC 8 subsidiaryofWlllillms 1001 ttl'Street, Suite 1200 Denver, CO 80202 303/527·3900

Ms. Kathleen Pasel' Duplicate submittal provided via e-mail to: MinorNSRPermittingCoordinator r8airpermitting@epa.gov 

# • U.S. EPA, Region 8 1595 Wynkoop Avenue. 8P-AR Denver, CO 80202-1129
Re: Synthetic Minor SourcePermit Application for the North Segment 6-7H Pad
Dear Ms. Paser: Dakota-3 E&P Company, LLC (Dakota-3) a subsidiary ofWilliams is submitting this Synthetic Minor Source Permit Application for the North Segment 6-7H Pad. This application is being submitted in accordance with the requirements ofFederal MinorNew Source ReviewRule. Do not hesitate to contact me with any questions either by phone at 303-606-4056, 01' bye-mail at JoDell.Mizoue@Williams.com
. Sincerely, Williams Dakota-3E&P CompallY, LLC 

# •

# t.~1f StaffEnvironmental Specialist Attachment
cc: File Joe GilliesJr. Environmental Director, Environmental Division, 204 W. Main, New Town,NO 58763-9404 Tex Hall, Chairman Three Affiliated Tribes, 404 Frontage Road, New Town, ND 58763-9404 (letterOnly) 

# •T



# • C. CONTACT INFORMATION



# • Company Contact: JoDell Mizoue 

# I Title:

, StaffEnvironmental

! Specialist Mailing Address: 1001 17th Street, Suite 1200 Denver, CO 80202 Email Address: JoDell.Mizoue@Williams.com Telephone Number: (303) 606-4056 •FacsimileNumber: (303) 692-8285 

## I 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 Compliance Contact: Same as above Title Mailing Address
Email Address TelephoneNumber FacsimileNumber



# •

# • D. ATTACHMENTS Include all ofthefo])owing information (see the attached instructions) ./ FORM SYNMIN

- New Source Review Synthetic Minor Limit Request Fonn, ifsynthetic minor limits are beingrequested
. ./ Narrative description ofthe proposedproductionprocesses. Thisdescription should follow 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 ofallproposed emission units and airpollution-generating activities
. ./ Type and quantity offuels, including sulfur content offuels, proposedto beused on a daily, annual and maximum hourly basis. ./ Type andquantity ofraw materials used or final product producedproposedtobeused ona daily, annual and maximum hourly basis
. ./ Proposed operating schedule, includingnumber ofhours per day, number ofdays per week and number of weeks per year. ./ A list and description ofall proposed emissioncontrols, control efficiencies, emission limits, and monitoring for each emissionunit and air pollution generatingactivity
. ./ CriteriaPollutantEmissions

- Estimates ofCurrent Actual Emissions, Current AllowableEmissions, PostChange Uncontrolled Emissions, and Post-ChangeAllowable Emissions for the following airpollutants: particulate matter, PM1O, PM2.5, sulfur oxides (SOx), nitrogen oxides (NOx), carbon monoxide (CO), volatile organic compound (VOC), lead (Pb) and lead compounds, fluorides (gaseous and particulate), sulfuric acid mist (H2S04), hydrogen sulfide (H2S), totalreduced sulfur (TRS) andreduced sulfur compounds, includingall calculations for the estimates
. ./ These estimates are tobe madefor eachemission unit, emissiongenerating activity, and theproject/facility in total. ./ Modeling

- Air Quality ImpactAnalysis (AQIA) ./ ESA (Endangered SpeciesAct) ./ NHPA (NationalHistoricPreservationAct 

# •

•



# •

# • E. TABLE OF ESTIMATED 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 forthe use specified at the top ofthe form. E(i)

- ProposedNew Facility



# • Pollutant Potential Emissions (tpy) ProposedAllowable Emissions (tpy) PM

- Particulate Matter PM 10 - 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 H2S04 - Sulfuric Acid Mist H2

S - Hydrogen Sulfide TRS

- Total Reduced Sulfur RSC

- Reduced Sulfur Compounds PM 0.51 0.63 PMu ) 0.51 0.63 PM 2.5 0.51 0.63

SOx 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 HIS 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) Kraftpulp mills; (c) Portland cementplants; (d) Primaryzinc smelters; (e) Iron and steel mills; (f) Primaryaluminum ore reduction plants; (g) Primarycopper smelters; 

# • (h)Municipal incinerators capable ofcharging more than 250 tons ofrefuse per day; (i) Hydrofluoric, sulfuric, or nitric acid plants; 

### til Petroleum refineries; (k) Lime plants; (I)Phosphaterock processingplants; (m) Coke oven batteries; (n) Sulfurrecoveryplants; (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 thereof) totaling more than 250million British thermal units perhour heat input; (v) Petroleum storage and transfer units with a total storage capacity exceeding 300,000barrels; (w) Taconite ore processingplants; (x) Glass fiber processingplants; (y) Charcoal production plants; (z) Fossil fuel-fired steam electric plants ofmore that 250million British thermal unitsperhour heat input, and (aa) Any other stationary source category which, as of August 7, 1980, is being regulated under section III or Il2 ofthe Act.



# •

# • E(ii) Proposed New Construction at an Existing Facility orModification ofan Existing Facility This section ofthe application is not applicable. The application is for a new facility only. 

### Pollutant Current Actual Emissions

Jtpy) Current Allowable Emissions (tpy) Post-Change Potential Emissions (tpy) Post-Change Allowable Emissions (tpy) PM 

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

### N/A N/A N/A N/A PM 2.5 

### 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 CO 

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

### 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

H1S04 

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

H1S 

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

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

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

# •

PM

- PartIculate Matter PM IO - Particulate Matterless than 10 microns 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 andlead compounds NH3

- Ammonia Fluorides

- Gaseous and particulates H

2S04 - Sulfuric Acid Mist H

2S - Hydrogen Sulfide TRS

- Total Reduced Sulfur RSC

- Reduced Sulfur Compounds 

# •



# •

# • Instructions Use ofThis Form

• Proposed new construction ormodifications should first be evaluatedto determine ifthe change is majorunder the majorNSRprogramusing the procedures at 40 CFR 52.21 (i.e., baseline actual to projected actual applicability test). Ifthe proposed constructiondoes not qualify as a majorunder that test, then it may be subject to the requirements ofthe minorNSRrule at 40 CFR49.151. 

### HelpfulDefinitions from the FederalMinorNSR Rule (40 CFR49)

- This is not acomprehensive list. 

# • 40 CFR 49.J 52(d)

- Modification means anyphysical oroperational change at a sourcethatwould cause an increase in the allowable emissions ofthe affected emissionsunits for anyregulated NSR pollutant orthat would cause the emissionofanyregulatedNSRpollutant not previously emitted. 

# • The following exemptions apply: (l) A physical oroperational change does not include routine maintenance, repair, orreplacement. (2) 

### An increase in the hours ofoperation orinthe productionrate is not considered anoperational changeunless such increase is prohibited underany federally-enforceable permit conditionor otherpermit conditionthat is enforceable as a practical matter. (3) A change in ownership at a source is not considered a modification.

• 40 CFR 49.J52(d)

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

• 52.2J(b)(J6)

-Allowableemissions means the emissions rate 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 StateImplementation Plan emissions limitation, including those with a future compliance date; or (iii) The emissions rate specified as a federally enforceablepermit condition, including those with a future compliance date.

Page 7of 15 

# •

# • A. General Facility Information I. CompanyName & OperatorName (ifdifferent): Provide the complete company and operatornames. For corporations, include divisions or subsidiary name, ifany. 2. Facility Name: Providethe facility name. Pleasenotethat a facility is a site, place, location, etc
... that may contain one ormore airpollution emittingunits. 3. Type ofOperation: Indicatethegenerally acceptedname 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 operatein more than onelocation? Someexamples ofportablesources include asphaltbatch plants and concretebatchplants. 5. Temporary Source: A temporary source, in general, would have emissions that are expectedlast less than 2 years. Do you expect to cease operations within thenext 2 years? 

# •
6. NAlCS Code: North AmericanIndustry Classification System. TheNAICS Codefor your facility canbe found atthe following link**~** North American Industry Classification System (bup://www.census.gov/epcdlnaics/nsic2ndx.htm#SI). 7. SIC Code: StandardIndustrial Classification Code. Although the newNorthAmericanIndustry Classification System(NAICS)hasreplacedthe SIC codes, much ofthe Clean Air Actpermittingprocesses continueto use these codes. TheSIC Codefor yourfacility canbefound atthe following link**~** Standard Industrial Classification Code (http://www.osha.gov/pls/imis/sic manual.html). 8. Physical Address: Providetheactual address ofwhere thefacility is operating, not the mailing address. Include the State and the ZIPCode. 9. Reservation: Providethe nameofthe Indianreservation within whichthefacility is operating. 10. County: Providethe Countywithin whichthefacility is operating. lla & lIb. Latitude & Longitude: These areGPS (globalpositioning system) coordinates. This information can be provided in decimal format or degree-minute-secondformat. 12a

- 12d. Section-Township-Range: Pleaseprovidethese coordinates in 114 SectioniSection/Township/Range. (e.g., SW 14, NE 114 /S36/TlONIR21E). 

# •

Page 8 of15 

# •

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

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

# • 2. OperatorContact: Provide the name ofthe operatorofthe facility ifit is different from the company contact. 3. FacilityContact: The facility contact must be the local contact authorized to receiverequests for data and information. 4. ComplianceContact: The compliance contactmust be the local contact responsible for the facility's compliance with this rule. Ifthis is the same as the Facility Contact please notethis on the form. 

### D. Attachments This section lists the information needed to complete the requested approval. This information shouldbe accompanied by the supporting information listed onthe form and describedbelow. The information should be presented inenoughdetailto document howthe 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 SYNMIN be included with this application
. ./ Narrativedescription ofthe proposedproductionprocesses. 

# • 1. The narrative description should follow the flow ofthe process flow diagramtobe submitted with this application. This needs to be as comprehensive as possible to help in understanding the proposed facility and how it will be operated. For example: What are the raw materials? What are the properties ofthe raw materials? Does theproductionprocess includeheating, drying, the application ofchemicals, etc? How will the raw materials be affectedby this process? What are the out puts from each step ofthe process (i.e., crushed ore, dry gas, water, etc
...)? Etc
.... 2. The proposed operating schedule presented in terms ofhours perday, daysperweek, and weeksper year. 3. A list ofthetype and quantity offuels and/orrawmaterials used. Each fuel and raw material should be described in enoughdetail to indicate its basic chemical components.
Page 9 of 15 

# •

# • ./ 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. ,f List and describe all proposedunits, emission units and airpollution-generating activities. At a minimum, provide the following: 1. The hourly, daily and annual maximum operating rates for each operatingunit, production process, and activity. 2. The hourly, daily and annual maximum firing rates for each fuel and combustion equipment. 3. The capacity for storageunits 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 and quantity offuels, including sulfur content offuels, proposed tobeusedon a daily, annual and maximumhourly basis
. ./ Typeandquantity ofrawmaterials used or final productproducedproposedtobeused ona daily, annual andmaximum hourlybasis
. ./ Proposedoperating schedule, includingnumber ofhours perday, numberofdays per week andnumber of weeksper year. ./ A list and description ofallproposedemissioncontrols, control efficiencies, emission limits, and monitoringfor each emissionunit andairpollution generating activity. I. Include manufacturer specifications and guarantees for each control device.



# •

Page 10 of 15 

# •

# •

•

A. GENERAL FACILITYINFORMATION 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. NAlCS Code 213111 

### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 8 AirProgram FEDERALMINORNEW SOURCE REVIEW PROGRAM IN INDIAN COUNTRY 

### CheckList

- Application for New Construction (FonnNEW) Please check all thatapply to show how you are using thisform

• Proposed Constructionofa New Facility 

### o Proposed ConstructionofNew Equipment atanExisting Facility 

## o Proposed ModificationofanExisting Facility 

### o Other

­ Please Explain Use oftblsInformatioD request form is voluntary and not yet approved bytheOffice ofManagement and Budget The following is acheck list ofthe typeofinformation thatRegion 8will use toprocess information on your proposed project. While submittal ofthis form is notrequired, itdoes offer details on the information we will useto completeyour requested approval and providing theinformation requested mayhelp expedite the process. Use ofapplication forms for this program iscurrently under Office ofManagement and Budget review and these information request forms will be replaced/updatedafterthat review is completed. Please submitinformationto following two entities: Minor NSR Permitting Coordinator U.S. EPA, Region 8 1595 Wynkoop Avenue, 8P-AR Denver, CO 80202-1129 TheTribal Environmental Contactfor the specific reservation: Ifyou need assistance in identifYing the appropriateTribal Environmental Contact and address, please contactthe EPA Region 8 Tribal AirCoordinator: Alexis North, EPA Region 8 Tribal AirCoordinator 303-312-7005 north.alexis@epa.gov

2. FacilityName North Segment 6-7HPad

4. Portable Source? 

# o Yes 5. Temporary Source? 

## 0 Yes**~** No**~** No 7. SIC Code 1311 8. Physical Address: 1001 1

### th Street, Suite 1200 Denver, CO 80202 9. Reservation* 110. County* 

# , 11a. Latitude* 11b. Longitude* Mountrail 47.84584 -102.38335 FBIR I 12a. QuarterQuarter Section* 12d. Range* 12b. Section* 

# I 12c. Township* NWNW 6 : TI50N R91W I 

# 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 ofthepermit application is not applicable. This application is for a new facility for which no previous permit actions have been taken. FacilityName on the Permit 

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

### N/A 

# I Dateofthe Permit Action 

### N/A 

# •



# •

•

# • Criteria PollutantEmissions Estimates ./ Estimates ofCurrent Actual Emissions, Current Allowable Emissions, Post-Change Uncontrolled Emissions, and Post-Change Allowable Emissions for the following air pollutants: particulate matter, PMJO, 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 all calculations for the estimates. I. These estimates are to be made for each emissionunit, emission generating activity, in addition tototal emissions. 

# • 2. The information should include all ofthe supporting calculations, assumptions and references. Emission estimates must address all emissionunits and pollutantsproposed and/or affectedbythe limitation and be presented in short term (e.g. poundsperhour) as well as annual (tons per year) units. 3. Any emission estimates submittedtothe 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; • Massbalance calculations; • Published, verifiable emission factors that are applicable to the source. (i.e. manufacturer specifications) • Otherengineering calculations; or • Otherprocedures to estimate emissions specifically approved by the Regional Administrator. 

### 4. Guidance for estimating emissions canbe found at http://www.epa.gov/ttnichiefJefuac/index.html
. Current Actual Emissions: Current actual emissions for a pollutant is expressed in tpyand generally is calculatedby multiplying the actualhourlyemissions rate inpoundsperhour (lbslhr) times actual hours operated (which is the numberofhours in a year) and dividing by 2,000 (which is the number ofpounds in a ton)
. 

# • I. For an existing air pollution source (permitted and unpermitted)that operatedpriorto the application submittal, the current actual emissions are the actual rateofemissions for the preceding calendaryear and must becalculatedusing the actual operatinghours, production rates, in-place control equipment, and types ofmaterials processed, stored, orcornbusted during thepreceding calendaryear. The emission estimates must bebasedupon actual test data or, in the absence ofsuch data, upon procedures acceptable to theRegional Administrator. Current Allowable Emissions: Current allowable emissions for a pollutant is expressed in tpy and generally is calculatedbymultiplying the allowed hourly emissions rate in pounds per hour (lbs/hr) times allowed hours (which is the number ofhours in a year) and dividing by 2,000 (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 (i.e., allowable emissions). The allowable emissions for any 

# • Page I I ofl5

# • emissions unit are calculated considering anyemissions limitations that are enforceable as a practical matteronthe unit's PTE. 2. For an existing permitted airpollution source that operatedpriorto the application submittal, the current allowable emissions are the allowable rate ofemissions for the preceding calendaryear and must be calculatedusing thepermittedoperating hours, production rates, in-place control equipment, and types ofmaterials processed, stored, orcombusted during theprecedingcalendaryear. 3. Foran existing air pollution sourcethat does not have anestablished allowable emissions level priorto the modification must report thepre-change uncontrolled emissions. Post-Change PotentialEmissions (Potentialuncontrolledemissions from proposedproject): This is the maximum capacityofa source to emit a pollutantunder its physical and operationaldesign. This is expressed in tpy and generally is calculatedby multiplyingthe maximum hourly emissions rateinpoundsperhour 

### (lbs/hr) times 8,760hOUTS (which is the number ofhoUTS in a year) and 

# • dividing by 2,000 (which is the number ofpounds in a ton). Post-Change Allowable Emissions: A source's allowable emissions for a pollutant is expressed in tpy and generally is calculatedbymultiplying the allowed hourly emissions rate in poundsperhour (lbslhr) times allowedhours (which is the number ofhours in a year) and dividing by 2,000 (which is the number ofpounds in a ton). 1. Unless the source is restrictedbypermit 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 lowerlevel ofallowable emissions maybe proposed. 2. Forphysicaloroperational changes at minor sources and for minorphysical oroperational changes at major sources, the total increase in allowable emissionsresulting from your proposed changewould be the sumoffollowing:

• For each new emissions unit that is to be added, the emissions increase would bethe potentialto emit ofeach unit. • Foreach emissions unit with an allowable emissions limit that is to be changed or replaced, the emissions increase wouldbethe allowable emissions oftheemissionsunit afterthe change orreplacement minus the allowable emissions priorto the change or replacement. However, this may not be a negative value. 

### Ifthe allowable emissions ofan 

# • emissions unitwould be reduced as a result ofthe change orreplacement, usezero in the calculation. • For each unpermitted emissions unit (i.e., aunit without anyemissions limitations before the change) that is to be changed orreplaced, the emissions increase wouldbe the allowable emissions ofthe unit afterthe change orreplacement minus thepotentialto emit priorto the change orreplacement. However, this may not be a negative value. Ifthe allowable emissions ofan emissionsunit would bereduced as a result ofthe change or replacement, use zero inthe calculation.

Page 12 of 15 

# •

# • ./ Modeling Analysis 

# I f

Do Ineed to do a mode1ing analysis? The FederalMinorNew Source Review Regulations at 40 CFR 49. 1 S9(d) requires that a modeling analysis (AQIA) ofproposed emissions be performed ifthere is reason tobeconcerned that new constructionwould 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 reducedbefore a pre-constructionpermit can

### be issued. To facilitate the protectionoftheNAAQS and PSD Increment, EPARegion 8 requests that those proposed activities that meet the following criteria perform an AQIA: 

# • 

# I I. The proposed activity has air emissions that EPA Region 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. 

# I 2. Modeling ofproposed emissions is usually warranted, even though the proposed activity does not meetthe modeling requirements, above, ifit is reasonable to believe the new activity may cause orcontribute to a violation ofapplicable ambient air quality standards orincrements in circumstances such as: (a) A substantialportion ofthe new ormodified emissions have poordispersion characteristics (e.g., rain caps, horizontal stacks, fugitive releases, or buildingdownwash) in close proximity to ambientairat the site boundary; (b) The new ormodified emissions are located in complexterrain (e.g., terrain above stack height inclose 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 benecessary based onthe 4th criteria above, please contactEPA Region 8'sModeling Lead: 

# • Gail Tonnesen Region 8 Modeling Lead Tonnesen.gail@epa.gov 

### 303-312- 6113

Page 13 of IS 

# •

# • What Kind ofAir Quality Modeling Analysis Is Needed? 1. EPA Region 8 considers a stepped or phased approach to modelingto be appropriate, as follows: Step 1: Qualitative Air Quality Assessment Step 

### 2: ScreeningModeling Analysis Step 3: Step4: Step 5: Step 6: PreliminaryModeling Analysis (refined modeling) Full Impact Modeling Analysis (refined modeling) PSD Increment and NAAQS Analysis Additional Impact Analysis 

### 2. Step 1: Qualitative Air QualityAssessment Narrative description ofthe current air quality conditions and the expected impactthe permitted source would have onthat air quality. Some suggested factors to consider inthe qualitative discussioncould include meteorology, terrain, distance to ambient air, expected emissions, etc. Ifa convincing case cannot be made qualitativelythat no impacts to air quality would be expected, a screening analysis should next be performed. 3. Step 

### 2: Screening Analysis Forproposed new ormodified sources that meet the modelingrequirement criteria identified above, protectionofair quality from proposed emissions may

### be shownby using a simple screeningtechnique (e.g., SCREEN3 or AERSCREEN). Screening models are available for download at the EPA SCRAM website: http://www.epa.gov/ttn/scramldispersionscreening.htm
. Apre-approved modeling protocol is not necessarypriorto conducting a Screening Analysis. 4. lfthe proposed new ormodified emission increases do not increase ambient concentrations ofa pollutant bymore thanthe significant impact levels, as compared to the SILs identified below, no further modeling is necessary. 

### S'

19m 'fi



### leantI

### mpact 

### Leve s Averaging Period Class IIArea SIL Class I Area SIL

Pollutant (uwm3) I 

### (uwm3) 3 ppbor7.8**ug/m~** (interim) I hr 

### ..

## --­ 25 3 hr 1.0 S02 24 hr 5 0.2 Annual I 0.08

24 hr 0.07 1.2 PM2
.5 Annual 0.06 0.3 

### I 24hr 5 0.2 PM10 Annual I 0.08 4 ppbor7.5**ug/m~** (interim) 

### ---... 1hr N02 Annual 1 0.08 2,OOOppb 1hr CO 8 hr 500ppb Note: TheClass I area SILs areprovided as guidance and have not been formalized by EPA.

Page 14 of 15 

# •



# •



# • i

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

### What Should I Include InMy Application If

### Modeling Is Necessary? 1. Approved Modeling Protocol In orderto expeditethe permitting process, it is recommended that you include a protocolthat has already been approved. 

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

# • 2. Modeling Results In all cases, the modeling results should include the name ofthemodel used, all input 

### f parameters, and the resulting output. Electronic copies ofthemodeling input/output files should be provided to EPARegion 8. 

# t ./ ESA I
The Endangered Species Act requires us, in consultationwiththe U.S. Fish and Wildlife Service and/or theNOAAFisheries Service, to ensure that actions we authorize are not likely tojeopardizethe continued existence ofany listed species orresult in the destruction oradverse modification of designated critical habitat ofsuch species. Toexpedite the approvalofyour proposed construction, we encourage you to identify any listed speciesthat you may be readily aware ofthat could be affected by yourproposal. The following website has been providedto assist you: http://www.fws.gov/endangeredl Simply enterthe State and County in which you propose to constructto obtain a general listing
. 

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

Page 15 of 15 

# •

# • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 8 AirProgram 

# &EPA FEDERAL MINOR NEW SOURCE REVIEWPROGRAM IN INDIAN COUNTRY 

### Checklist

- SyntheticMinorLimitRequest (Fonn SYNMIN) Use ofthisinformation request form is voluntary and not yet approved by the Office ofManagement and Budget. The following is acheck list ofthe type ofinformation that Region 8will use toprocess information on your proposed project. While submittal ofthis form is notrequired, it does offer details on the information we will use to complete your requested approval and providing the information requested mayhelp expedite the process. Use ofapplication forms for this program is currently under Office ofManagement and Budgetreview and these information request forms will be replaced/updatedafterthatreview is completed. Please submitinformationto following two entities: TheTribal EnvironmentalContactfor the specific reservation: Ifyouneedassistance in identifyingthe appropriateTribal Environmental Contactand address, please contact the EPA Region 8 Tribal Air Coordinator: 

# • FederalMinorNSRPermit Coordinator U.S. EPA, Region 8 1595 Wynkoop Avenue, 8P-AR Denver, CO 80202-1129
Alexis North, EPA Region 8 Tribal Air Coordinator 303-312-7005 north.alexis@epa.gov 

### A. GENERAL INFORMATION



# • Foreach criteria airpollutant, hazardous airpollutant and for all emission units and airpollutantgenerating activities to becovered by a limitation, includethefollowing: B. ATTACHMENTS

./' Item 1 - Theproposedlimitation anda description ofits effect oncurrent actual, allowable andthepotentialto emit. ./' Item 2 - Theproposedtesting, monitoring, recordkeeping, andreportingrequirements tobeusedto demonstrate and assurecompliancewith theproposedlimitation
. ./' Item3 - A description ofestimated efficiencyofairpollutioncontrol equipment under present or anticipated operating conditions, including documentation ofthe manufacturer specifications andguarantees
. ./' Item4 - Estimates ofthe Post-Change AllowableEmissions that wouldresult from compliancewith the proposed limitation, including all calculations for the estimates
. ./' Item5 - Estimates ofthepotential emissions ofGreenhouseGas (GHG) pollutants before and after proposed emissioncontrols. 

# • Company Name FacilityName Dakota-3 E&P Company, LLC North Segment 6-7HPad Company ContactorOwnerName Title JoDell Mizoue StaffEnvironmental Specialist Mailing Address 1001 17th Street, Suite 1200 Denver, CO 80202 Email Address JoDell.Mizoue@Williams.com TelephoneNumber FacsimileNumber (303) 606-4056 (303) 692-8285

# • i t

Instructions Use this form to provide general and summary information about the synthetic minorNSR source (facility orplant) on Tribal lands and to indicatetheemissions limitations requested. Submit thisform once, in addition toFORMNEW, for each synthetic minorNSR sourceon Tribal lands.
1. 

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

# • The Tribal NSRRule applies onlyto sources located withinthe exteriorboundaries ofan Indian reservation in the United States ofAmerica orother lands as specified in40 CFRpart 49, collectively referred to as "Indian country". So, to usethe authority in the Tribal NSRRule to create federallyenforceable limitations, a facility must be located within Indiancountry. Land ownership status (for example, whetherthe land is owned by a Tribal member orwhetherthe land is owned in fee orintrust) does not affect howthe rule applies. 

### 2. Who Might Wantto Request Federally-Enforceable Limitations? The primaryreason for requesting federally-enforceable limitations is to avoid anotherwise applicable federal CleanAir Actprogram, rule orrequirement. Many federal CleanAir Act programs use a source's "potentialtoemit" (PTE) air pollutionto determine which rules orrequirements apply. A facility's PTE is based onthe maximum annual operational (production, throughput, etc) rate ofthe facility taking into considerationthe capacityand configuration ofthe equipment and operations. Emission oroperational limits can also betaken into consideration as maximums iftheyare federally enforceable. So, using a synthetic minor NSRpermit to establish federally enforceable limitations can lower a facility's PTE and possibly allow the facility to avoid certain federal CleanAir Act requirements. Three examples offederal Clean Air Actprograms that use PTEto determine whether theyapply are (I) the PreventionofSignificant Deterioration (PSD) constructionpermittingprogram, (2)theTitle V operatingpermitprogram, and (3) the Maximum Achievable Control Technology (MACT) program. For example, existing sourcesthat are considered "major" for Title V (meaning they have the potential to emit airpollution at levels defined inthat rule as "major") must apply for a Title V operating permit. Ifa source accepts a federally-enforceable limitationthrough a synthetic minorNSRpermitthat reduces their PTEtobelow the "major" threshold, and the source doesnot meet anyofthe other requirements that would trigger applicability to the part 71 program, thenthe source nolonger needs a Title V operatingpermit. Whenplanning for the constructionofa new source orexpansion ofan existing source, a source can also accept limitations onPTE (using a synthetic minorNSRpermit) that allowthe sourceto avoid PSD. Limitations onPTE can similarly help a source to avoid newMACT standards that would otherwise apply tothe source. 

### 3. Section B. AITACHMENTS This section lists the informationthat must be attached to the application form for each requested limitation. Therequested limitation(s) must be described for each affected emissions unit (orpollutantgenerating activity) and pollutant and mustbe accompanied bythe supporting information listed onthe form and described below. Notethat applicability ofmany federal CleanAir Act requirements (such as Title V, PSD and MACT) is oftenbased on facility-wide emission levels ofspecific pollutants. In that 

# • Page 2 of4

# • case, an emissions units at a facility and all pollutants regulated by that givenrule orregulation must be addressedby this section ofthe application form. Item 1

- The requested limitation and its effect on actual emissions orpotentialto emit must be presented in enough detail to document howthe limitationwi1llimit the source's actual orpotential emissions as a legal and practical matter and, ifapplicable, will allow the sourceto avoid an otherwise applicable requirement. The informationpresented must clearly explain how the limitation affects each emissionunit and each air pollutant from that emissionunit. Use the informationprovided inresponse to Item4 below toexplain howthe limitation affects emissions before and after the limitation is in effect. Item 

### 2 - Foreachrequested limitation, the application must include proposed testing, monitoring, recordkeeping andreporting that will be used to demonstrate and assure compliance with the limitation. Testing approaches should incorporate andreference appropriate EPAreference methods where applicable. Monitoring should describethe emission, control orprocessparameters that will be relied on and should address frequency, methods, and quality assurance. Item 3

- The application must include a description and estimated efficiency ofairpollutioncontrol equipmentunderpresent or anticipated operating conditions. For controlequipment that is not proposed to be modified to meet therequested limit, simply note that fact; however, for equipment that is proposed tobe modified (e.g. improved efficiency) ornewly installed to 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 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: (i) Source-specific emission tests; (ii) Mass balance calculations; (iii) Published, verifiable emission factors that are applicable to the source. (i.e., manufacturer specifications). (iv) Other engineering calculations; or (v) Otherprocedures to estimate emissions specifically approvedbythe Regional Administrator. Post-ChangeAllowable Emissions: A source's allowable emissions for a pollutant is expressed in tpy and generally is calculated by multiplying the allowedhourly emissions rate inpounds perhour (lbslhr) times allowedhours (which is the number ofhours in a year) and dividing by 2,000 (which is the number ofpounds in a ton). Item 5 - JI:lew constructionprojects that have the potentialto emit GHG emissions ofat least 100,000 tpy C02e and 100 or250 tpy ona mass basis, modifications at existing PSD facilities that increase GHG emissions by at least 75,000 tpy C02e and minor sourcesthat increase GHG emissions by at least 100,000 tpy C02e and 100 or250tpyona mass basis are subject to PSD permittingrequirements, even ifthey do not significantly increase emissions ofany otherpollutant. As such, any requested limits to avoid PSD must take into account greenhouse gases. Therefore, please include in your permit application estimates ofthepotential emissions ofthe following pollutants before and after proposed emissioncontrols. More information about GHG permitting andhow to calculate CO2equivalents (C02e), the mass emissions ofeach individual GHG 

# •



# •

• Page 3 01'4

# • adjusted for its Global Warming Potential (GWP) can 

### be found at: http://epa.gov/nsr/ghgdocs/ghgpermittingguidance
.pdf 1. Carbon dioxide (C02) 2. Methane**(C~)** and its C02e 3. Nitrous oxide (N20) and its C02e 4. Hydrofluorocarbons (HFCs) and its COze 5. Perfluorocarbons (PFCs) and its C02e 6. Sulfur hexafluoride (SF6) and its COze


# •

•



# • Page 4 of4

# •
NORTH SEGMENT6-7H 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



# •

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

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# •

ATTACHMENTA: APPLICATION REPORT



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•

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

# t

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# • APPLICATION FORAN NSR PSD/TITLE V SYNTHETIC MINOR AIR QUALITY PERMIT

NORTH SEGMENT 6-7H PAD OIL & 

# GAS PRODUCTION FACILITY

Prepared for: 

### Dakota-3E&P Company, LLC 100117th 

### Street, Suite 1200 Denver, CO 80202

Preparedby: 

### Bison Engineering,Inc. 1400 11th Avenue 

# I
Helena, MT 59601 I 

# • 

# I I (406) 442-5768 www.bison-eng.com 

# I ! I 

# i**~**

# I**~ ~** 

# I I I December 28, 2011

# • TABLE OFCONTENTS 1.0 INTRODUCTION

.................................................................................................. 1 1.1 Summary

................................................................................................... 1 1.2 Site Location

.............................................................................................. 1 1.3 Site Description

.......................................................................................... 1 2.0 NARRATIVE DESCRiPTION

................................................................................2 3.0 POTENTIAL TO EMIT ESTIMATE

.......................................................................4 3.1 Production Storage Tank VOC Emissions

................................................. 7 3.2 Produced Casing Head Gas Emissions

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

# • 3.3 ReCiprocating Internal Combustion or Compression Ignition Engines

....... 8 3.4 Natural Gas External Combustion Unit Emissions

..................................... 8 3.5 Truck Loading Emissions

...........................................................................8 3.6 Fugitive Emissions: Dust and Equipment Leaks

....................................... 8 4.0 EMISSIONS AND OPERATIONAL LIMITS REQUESTS

..................................... 9 4.1 Production Storage Tank Emissions

..........................................................9 4.2 Reciprocating Internal Combustion or Compression Ignition Engines

....... 9 5.0 ALLOWABLE EMISSIONS

................................................................................. 10 5.1 Storage Tank Emissions

.......................................................................... 10 5.2 Produced Casing Head Gas Emissions

................................................... 10 5.3 Rice Engine Emissions

............................................................................ 10 5.4 Natural Gas External Combustion Unit Emissions

................................... 10 5.5 Truck Loading Emissions

......................................................................... 11 5.6 Fugitive Emissions: Dust and Equipment Leaks

..................................... 11 5.7 Diesel Storage Tank Emissions

............................................................... 11 6.0 PROPOSED MONITORING AND RECORDKEEPING

...................................... 12 6.1 Production Storage Tanks

....................................................................... 12 6.2 Production Storage Tank Emissions Control Device

............................... 13 6.3 Produced Casing Head Gas Emergency Utility Flare

.............................. 15 

# • 6.4 Rice Engines

............................................................................................ 16 6.5 Natural Gas-Fired External Combustion Units

......................................... 16 6.6 Truck Loading

.......................................................................................... 17 6.7 Fugitive Emissions: Dust and EqUipment Leaks

..................................... 17 6.8 General Recordkeeping Requirements

.................................................... 19 7.0 QUALITATIVE AIR QUALITY ASSESSMENT

....................................................20 8.0 ENDANGERED SPECIES ACT

..........................................................................21 9.0 NATIONAL HISTORIC PRESERVATION ACT

..................................................22

North Segment 6-7H Pad 12/28/11 pg. ii NSR Synthetic Minor Permit Application Project#: WEP211324 

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

.................,................. 6 Figure 2: Example of Actual 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 FacUity Production Dedine Curve Calculations Diesel Tank EPATANKS 4.09d Emissions Summary



# •

North Segment 6·7H Pad 12/28111 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 North Segment 6-7H 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 North Segment 6-7H Pad is proposed to be located in the northwest**~** 

### of the northwest**~** 

### Section 6, Township 150 North, Range 91 West, Mountrail County, on the FBIR in North Dakota. 

### 1.3. Site Description At the proposed North Segment 6-7H 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. North Segment 6-7HA 2. North Segment 6-7HB 3. North Segment 6-7HC 

# • 4. North Segment 6-7HX 5. North Segment 6-7HW 6. North Segment 6-7HY 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.

North Segment 6·7H Pad pg. NSR Synthetic Minor Permit Application Project #: WEP211324 

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2.0 NARRATIVE DESCRIPTION This section of the application provides a detailed description of the operations at the North Segment 6-7H 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 in when 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 - HeaterTreater/Separators 6 - Line-Heaters (0.75 MMBtu/hr max) 30 - Oil Production Tanks 1 - Gasoline Recycling Pump 12 - Produced WaterTanks 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 wellbore 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 treaterthe 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
North Segment 6-7H Pad 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 offsite 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 recycle the liquids (oil/water) in the bottom ofthe 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. Onsile 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. 

# • i I



# •

North Segment 6·7H Pad 12/28111 pg. 3 NSR Synthetic Minor Permit Application Project#: WEP211324 

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# •
3.0 POTENTIALTO EMITESTIMATE 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 ofthe 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 rolling 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. 

# •



# •

• North Segment 6-7H Pad 12/28111 pg.4 NSR SynthetiC Minor Permit Application Project #: WEP211324

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# • •

•••••••••••••••••••••• 

# •**,",.~_.,._. ~_.~,..~~**  

### ..**~~** 

### ..,**".~~,**

### ..,."."
...**~_.·** 

### ••**.,"".~w~._.,,_,~_** 

### •.**~_** 

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### ..



### 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 

### simuRaneou:sf\{ 

# R'OOO 

# •

liD • 

# '" 

# looo •• • Total Production from Seven 

# f • We'Is on Pad 

# i ••• 2,000
. • ....

1,000



### o o 10 20 30 40 Month

North Segment 6-7H Pad 12128111 pg.5 NSR Synthetic Minor Pennit Application Project#: WEP211324

# • • 

# • • Figure 2: Example ofActualProduction from a Seven Well Pad 

## Example ofActual Production From aSeven-Well Well Pad 3,500 

## Lt' 6th and 7thwells begin production 3,000

2,500
Q c.. 

### g G/ 2,000 

## If G/ 5th well begi ns production

2nd well begins production 1st well begins production -+-Total Production from Seven Wells on Pad**~** ---12-Month Rolling Average Oil Production 2:­ 

# ..s 1,500 

# i -12-Month Rolling Average Oil Production limit
1,000

500

o 

### o 5 10 15 20 25 30 35 40 Month
North Segment 6-7H 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 (i.e., 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 (HeaterTreater 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 Casing Head 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 North Segment 6-7H Pad 12128111 pg. 7 NSR Synthetic Minor Permit Application Project#: WEP211324 

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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 Reciprocating Internal Combustion orCompression 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 1111 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 Btu/hr. The emissions are based on AP-42 factors and assume the heater is running 8,760 hours peryear. 

### 3.5 TruckLoading Emissions 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 near future, 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.

North Segment 6-7H Pad 12/28111 pg.8 NSR Synthetic Minor PermitApplication Project#: WEP211324 

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4.0 EMISSIONSAND OPERATIONALLIMITS REQUESTS Oatoka-3 is requesting emissions and operational limits at

# the~~~~**rrtrPad.(i~~7Ier** to obtain a synthetic minor status with regard to the NSR permitting programs. The federally enforceable permit conditions will allow Oakota-3 to operate the facility while emitting less than the PSOlTitle V major source thresholds of250/100 

### tons per year ofa 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, Oakota-3 will control the storage tank vac and HAP emissions by installing an enclosed 

# f smokeless combustion device that has been independently tested and certified to exceed the requirements of 40 CFR 60.18 at 98% destruction efficiency (ORE). 

# I 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 ofvacs and 0.26 tons per year of HAPs. 

### 4.2 ReciprocatingInternal Combustion or Compression IgnitionEngines Oakota-3 will be required to limit the emissions from any reciprocating internal 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.


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North Segment 6-7H Pad 12/28/11 pg.9 NSR Synthetic Minor Permit Application Project#: WEP211324 

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## 5.0 ALLOWABLE EMISSIONS 

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•

• 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 CH4emissions. Although the VOC, HAP, and CH4 emissions are reduced by the smokeless combustion device, CO, NOx, 

### PM, PM1O. PM2.5 and N2 0 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 two· phased 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.

North Segment 6-7H Pad 12128/11 pg. 10 NSR Synthetic Minor Permit Application Project #: WEP211324

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5.5 TruckLoading Emissions 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 Equipment Leaks



# • 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 twelvemonth 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.



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North Segment 6-7H Pad 12/28/11 pg. 11 NSR Synthetic Minor Permit Application Project #: WEP211324 

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6.0 PROPOSED MONITORINGAND RECORDKEEPING As per the Application for Synthetic Minor Limit Request (Form SYNMIN), Page 1 

### (8), 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/working/breathing 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 of the 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. 

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# • North Segment 6-7H Pad 12/28/11 pg.12 NSR Synthetic Minor Permit Application Project#: WEP211324

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• Recordkeeping Requirements: In order to demonstrate compliance with the 12-month rOiling 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 VOC, 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 Control Device 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 VOC (or VOC 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 suffident 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 

### °C, or ±2.5 

### °C; 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 flame fails; 

### f. Maintained in a leak-free condition; and g. Operated in a smokeless mode. North Segment 6-7H Pad 12/28111 pg.13 NSR Synthetic Minor PermitApplication Project#: WEP211324

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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 or vendor 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 or the 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 of any instances in which the pilotflame 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 or the 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.
North Segment 6-7H Pad 12/28111 pg.14 NSR Synthetic Minor Permit Application Project#: WEP211324

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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 ofsuch 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 pilot flame; 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 Head Gas 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 of gas 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 VOC (or VOC 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. North Segment 6-7H Pad 12/28/11 pg. 15 NSR Synthetic Minor Permit Application PrOject#: WEP211324 

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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 °C, or ±2.5 °C; 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 ZZZZ, 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-Fired External Combustion 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.

North Segment 6-7H Pad 12/28/11 pg.16 NSR Synthetic Minor Permit Application Project #: WEP211324

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### 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 atthis 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 after the 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 North Segment 6-7H Pad 12/28/11 pg.17 NSR Synthetic Minor Permit Application Project#: WEP211324 

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leak is detected. Dakota-3 will minimize leaks of volatile organics from each piece of equipment in hydrocarbon service atthis 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 semiannual. 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 or greater 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 or greater 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.

North Segment 6-7H Pad 12/28/11 pg. 18 NSR Synthetic Minor Permit Application Project#: WEP211324

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• Recordkeeping Requirements:
a. Dakota-3 will document and maintain a record ofeach leak detection inspection and repairs. b. All leak detection inspection records wi" indude. 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. Priorto 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, 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
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North Segment 6-7H Pad 12128111 pg.19 NSR Synthetic Minor Permit Application Project#: WEP211324 

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## 7.0 QUALITATIVE AIR QUALITYASSESSMENT 

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# .' 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 of air 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 near the 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.

North Segment 6-7H Pad 12/28/11 pg.20 NSR Synthetic Minor Permit Application Project #: WEP211324

## 8.0 ENDANGERED SPECIESACT 

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# • 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 ofdesignated critical habitat ofsuch 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/northdakotafieldotfice/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 determine 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

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North Segment 6-7H Pad 12/28/11 pg.21 NSR Synthetic Minor PermitApplication Project#: WEP211324 

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## 9.0 NATIONALHISTORIC PRESERVATIONACT 

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• 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 of the 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.

North Segment 6-7H Pad 12128111 pg.22 NSR Synthetic Minor Permit Application Project#: WEP211324

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ATTACHMENT B: EMISSION INVENTORY



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

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# 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.