UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX
75 Hawthorne Street San Francisco, CA 94105

PROPOSED

PREVENTION OF SIGNIFICANT DETERIORATION

PERMIT

ISSUED PURSUANT TO THE REQUIREMENTS AT 40 CFR § 52.21

U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 9

PSD PERMIT NUMBER: N U 05

- 01

PERMITTEE: Resolute Natural Resources Company 1675 Broadway, Suite 1950 Denver, Colorado 80202

FACILITY NAME McElmo Creek Unit Oil Production Facility

FACILITY LOCATION: Section 31, Township 40 South, Range

25 East w ithin the Four Corners Area on the Navajo Nation Indian Reservation near the city of Aneth, San Juan County, Utah

Pursuant to the provisions of the Clean Air Act (CAA), Subchapter I, Part C (42 U.S.C. § 7470,

et. seq. ), and the Code of Federal Regulations (CFR) Title 40, Section 52.21, the United States Environmental Protection Agency (EPA)

, Region 9 (EPA) is issuing this amended Prevention of Significant Deterioration (PSD) air quality permit to Resolute Natural Resou rces Company (Resolute) for the McElmo Creek Unit Oil Production Facility as described herein, in accordance with the permit application (and plans submitted with the permit application)

, federal regulations governing the Prevention of Significant Deterior ation of air quality (40 CFR § 52.21), and other

terms and conditions set forth in this amended PSD Permit.

Failure to comply with any condition or term set forth in this amended PSD Permit is subject to enforcement action pursuant to Section 113 of the Clean Air Act. This permit does not relieve

Resolute from the responsibility to comply with any other applicable provisions of the CAA (including applicable impleme nting regulations in 40 CFR P arts 51, 52, 60, 61 and 63), or other federal, tribal, and local requirements.

Per 40 CFR § Section 124.15(b), this PSD Permit becomes effective 30 days after the service of notice of this final permit decision unless review is requested on the permit pursuant to 40 CFR § Section 124.19.McElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 2

Elizabeth J. Adams Acting Deborah Jordan Director, Air Division DateMcElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 3 ABBREVIATIONS & ACRONYMS

Act Clean Air Act [42 U.S.C. § 7401 et seq.] Applicant Resolute Natural Resources Company

BACT Best Available Control Technology

BTU British thermal units

CAA Clean Air Act [42 U.S.C. § 7401 et seq.]

CEMS Continuous Emissions Monitoring System

CFR Code of Federal Regulations

CMS Continuous Monitoring System

CO Carbon Monoxide

CO 2 Carbon Dioxide

CPMS DSCFM Continuous Parameter Measurement S ystem Dry standard cubic feet per minute

EPA United States Environmental Protection Agency

H 2 S Hydrogen Sulfide

h p HHV Horsepower Higher Heating Value

hr H our lb, lbs P ound, pounds

MCU Facility / Facility McElmo Creek Unit Oil Production Facility

m in Minute

MMBTU Million British thermal units

MM CFD Million cubic feet per day NAAQS National Ambient Air Quality Standards

NHV dil NES HAP Net heating value of dilution National Emission Standards for

Hazardous Air Pollutants

NHV vg NNEPA Net heating value of vent gas Nava jo Nation Environmental Protection Agency

NO
x Oxides of n itrogen

O 2 Oxygen

Permittee / Owner or Operator Resolute Natural Resources Company, or the owner and/or operator of the McElmo Creek Unit Oil Production Facility

ppm Parts per million

PSD Prevention of Significant Deterioration

PTE Potential to Emit

scf SCF Standard cubic feet

scfm SCFM Standard cubic feet permit minute

SO 2 Sulfur Dioxide

SO
x Oxides of s ulfur

tpy Tons per y earMcElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 4

VOC Volatile Organic Compounds as defined in 40 CFR § 51.100(s)McElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 5 

### MCELMO CREEK UNIT OIL PRODUCTION FACILITY

PREVENTION OF SIGNIFICANT DETERIORATION PERMIT

PERMIT CONDITIONS

PROJECT DESCRIPTION

The McElmo Creek Unit Oil Production Facility (MCU Facility or Facility) is an existing oil and gas production operation located within the Four Corners Area on the Navajo Nation Indian Reservation near the city of Aneth, San Juan County, Utah. The Facility is owned, in partnership

with the Navajo Nation Oil and Gas Company, and operated by the Resolute Natural Resources Company. The Facility is on the McElmo Creek Unit oilfield

, which includes field operations and a gas compression plant.

The field operations consist of approximately 90 producing wells where petroleum crude oil is recovered from producing strata, and brought to the surface to be stored at either a satellite or a tank battery (i.e., in general, a sub

- tank battery that is located between wells and the main tank battery) or a main tank battery.

. There are eleven satellite tank batteries satellites that function as testing facilities for producing wells and four main tank batteries.

The gas compression plant serves tertiary oil recovery operations for the McElmo Creek Unit

oi lfield. The gas compression plant receives produced gas through a gathering system, pressures the gas up to a suitable working pressure, and re

- injects the gas to maintain reservoir pressure in the oilfield. The natural gas is injected with produced wate r in a dual injection system. Due to varying water injection demands in the field, and to the number of wells being serviced at any time, the gas compression p lant inlet volume can vary between 10 and 18 million standard

cubic feet per day (MMSCFD)

. The Main Flare is located at the gas compression plant.

This PSD Permit amendment revises incorporates requirements of the existing PSD permit by incorporat ing f ederal Consent Decree that applies to the MCU Facility ’s Main Flare ( see United

States v. Mobil Exp loration and Producing U.S. Inc., Case No. 2:05

– CV

– 319, filed June 8, 2005) , which include Best Available Control Technology (BACT) requirements for the Main Flare, including emission limitation s for emissions of sulfur dioxide (SO 2 ), nitrogen oxides (NO
x ), carbon monoxide (CO), and volatile organic compounds (VOC). A ir pollution emissions associated with this permit amendment will not cause or contribute to violations of any National Ambient Air Quality Standards (NAAQS) or any applicable PSD increments for the pollutants regulated under the PSD permit.McElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 6 EQUIPMENT LIST

The following devices and acti vities are subject to this PSD P ermit

.

Unit ID Description

Main Flare One (1) air

- assist flare , rated at 618,104 scf/hr, which combusts produced field gas in excess of the facility compression capacity

Glycol Dehydrator TEG

Reboiler One (1) Glycol Dehydrator with o ne (1) T riethylene Glycol ( TEG ) Reboiler rated at 0.75 MMBtu/hr, which combusts purchased pipeline quality natural gas to provide heat to the Glycol Heater

Glycol Heater One (1) Glycol Heater (TEG regenerator), rated at 12 MM CFD

, which provides inter

- stage dehydration for the HOS

- 6 com pressor

Gasoline Storage Tank One (1) 10,000 gallon nominal capacity gasoline storage tank that is used for refueling of vehicles

Aerial C

- 5 Compressor Ariel JGD

- 6 electrically

- driven compressor

, driven by a Reliance model 9240 AC induction motor rated at 2,500 hp

HOS

- 4 Compressor Dresser Rand HOS

- 4 electrically

- driven compressor

, driven by a General Electric model EK AC induction motor rated at 2,000 hp

HOS

- 6 Compressor Dresser Rand HOS

- 6 electrically

- driven compressor

, driven by an Allis Chalmers model 6802 AC induction motor rated at 5,000 hp

Acid Gas A Compressor Worthington Cub

- 4 electrically

- driven compressor

, driven by a Westinghouse model 6808 AC induction motor rated at 400 hp

Aci d Gas B Compressor Worthington Cub

- 4 electrically

- driven compressor

, driven by a Westinghouse model 6808 AC induction motor rated at 400 hp

PERMIT CONDITIONS

I. PERMIT EXPIRATION

As provided in 40 CFR § 52.21(r), this PSD Permit shall become invalid if construction:

A. is not commenced (as defined in 40 CFR § 52.21(b)(9)) within 18 months after the approval takes effect; or

B. is discontinued for a period of 18 months or more; or

C. is not completed within a reasonable time.McElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 7 II. PERMIT NOTIFICATION REQUIREMENTS

The Permittee shall notify the EPA Region 9 IX by letter or by electronic mail of the:

A. date construction is commenced, postmarked within 30 days of such date;

B. actual date of initial startup, as defined in 40 CFR § 60.2, postmarked within 15 days of such date;

C. date upon which initial performance tests will commence postmarked not less than 30 days prior to such date. Notification may be provided with the sub mittal of the performance test protocol; and

D. date upon which initial performance evaluation of the continuous emissions monitoring system (CEMS) will commence in accordance with 40 CFR § 60.13(c), postmarked not less than 30 days prior to such date. Not ification may be provided with the submittal of the CEMS performance test.

III. FACILITY OPERATION

A. At all times, including periods of startup, shutdown, shakedown, and malfunction,

the Permittee shall, to the extent practicable, maintain and operate the Faci lity

, including associated air pollution control equipment

, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be

based on information available to the EPA, which may include, but is not limited to, monitoring results, opacity observations, review of operating maintenance procedures

, and inspection of the Facility.

B. The operating staff with management authority at this F acil ity shall be advised of

and be familiar with all the conditions of this PSD Permit.

IV. GENERAL MALFUNCTION REPORTIN G

A. The Permittee shall notify the EPA at AEO_R9@epa.gov R9.AEO@epa.gov within two (2) working days following the discovery of any failure of air pollution control equipment or process equipment, or failure of a process to operate in a normal manner, which results in an increase in emissions above the

allowable emission limits stated in Section IX of thi s permit.

B. In addition, the Permittee shall provide an additional notification to the EPA in writing or electronic mail within fifteen (15) days of any such failure describedMcElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 8 under Condition IV.A. This notification shall include a description of the malfunctioning equipment or abnormal operation, the date of the initial malfunction, the period of time over which emissions were increased due to the failure, the cause of the fai lure, the estimated resultant emissions in excess of

those allowed in Section I X, and the methods utilized to mitigate emissions and restore normal operations.

C. Compliance with this malfunction notification provision shall not excuse or

otherwise constit ute a defense to any violation of this permit or any law or regulation such malfunction may cause.

V. RIGHT OF ENTRY

A. The EPA and its contractors, consultants, and agents shall have authority to enter the Facility at all reasonable times, and upon presentat ion of credentials, shall be permitted to :

1. E nter the premises where the Facility is located or where any records are required to be kept under the terms and conditions of this PSD Permit;

2. During normal business hours, have access to and to copy any reco rds required to be kept under the terms and conditions of this PSD Permit;

3. In spect any equipment, operation, or method subject to requirements in this PSD Permit; and

4. S ample materials and emissions from the Facility

.

B. This provision in no way limits or otherwise affects any right of entry held by the EPA pursuant to applicable federal, state, or local laws, regulations, or permits.

VI. TRANSFER OF OWNERSHI P

In the event of any changes in control or ownership of the Facility, this PSD Permit shall be binding on all subsequent owners or operators. Within 14 days of any such change in control or ownership, the Permittee shall notify the succeeding owner or oper ator of the existence of this PSD Permit and its conditions by letter . The Permittee shall send a copy of this letter to the EPA Region 9 IX within thirty (30) days of its issuance

.

VII. SEVERABILITYMcElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 9 The provisions of this PSD Permit are severable, and, if an y provision of the PSD Permit is held invalid, the remainder of this PSD Permit shall not be affected.

VIII. ADHERENCE TO APPLICA TION AND COMPLIANCE WITH OTHER

ENVIRONMENTAL LAWS

The Permittee shall construct in accordance with this PSD Permit , the application on which this permit is based

, and all other applicable federal, state, and local air quality regulations. This PSD P ermit does not release the Permittee from any liability for compliance with other applicable federal, state

, and local environmental laws and regulations, including the Clean Air Act.

IX. SPECIAL CONDITIONS FOR THE MAIN FLARE

A. Definitions

1. “CO 2 Breakthrough” shall mean an event where a gas or fluid injected in the Facility’s oil field for the purpose of promoting the production of oil contacts a producing well and results in an increase in gas volume to compressor station equipment.

2. “Day” shal l mean a calendar day, unless expressly stated to be a working day. In computing any period of time under Section IX of this PSD

Permit , where the last day of such period would fall on a Saturday, Sunday, or federal holiday, the period shall run until the close of business on the next day that is not a Saturday, Sunday, or federal holiday.

3. “Facility” shall mean the Permittee’s McElmo Creek Unit Oil Production Facility and associated oil fields, located near Aneth, Utah, on the Navajo

Nation Indian Reserva tion

.

4. “Field Flares” shall mean the following flares at the Facility: (i) Tank Battery Flares at MCU Area 1 Battery, MCU Area 2 Battery, MCU Area 4 Battery, and MCU Area 6 Battery; and (ii) Satellite Flares at MCU Section 2, MCU Section 3, MCU Section 5 , MCU Section 6, MCU Section 9, MCU Section 11, MCU Section 17, MCU Section 19, MCU Section 32,

and MCU Section 33.

5. “Flaring Incident” shall mean continuous or intermittent flaring at the

Main Flare that results in the emissions of SO 2 equal to, or greate r than,

five

- hundred ( 500 ) pounds in any twenty

- four ( 24

- ) hour period; provided, however, that if five

- hundred ( 500 ) pounds or more of SO 2 have beenMcElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 10 emitted in a twenty

- four ( 24

- ) hour period and the flaring continues into subsequent, contiguous, non

- over lapping twenty

- four ( 24

- ) hour period(s), each period of which results in emissions equal to, or greater than, five hundred (500) pounds of SO 2 , then only one Flaring Incident shall have occurred. Subsequent, contiguous, non

- overlapping periods are measur ed from the initial commencement of flaring within the Flaring Incident.

6. “Main Flare” shall mean the flare installed as part of the Facility’s former gas processing plant.

7. “Main Flare Emissions” shall mean the emissions from the Main Flare at

the Facility as well as all emissions that result from: (1) combustion of fuel gas in the Main Flare’s pilot, (2) the closed drain and filter backwash operations, (3) CO 2 Breakthroughs, (4) any Scheduled Maintenance, and (5) unscheduled maintenance of the Fac ility’s compressors.

8. “Malfunction” shall mean , for the purposes of reporting under Condition

IX. H I .3 of this PSD Permit only

, any sudden and unavoidable breakdown of process or pollution control equipment. CO 2 Breakthroughs and

Scheduled Maintenance of t he Facility’s compressors are not

Malfunctions.

9. “Root Cause” shall mean the primary cause of a Flaring Incident as determined through a process of investigation; provided, however, that if a Flaring Incident encompasses m ultiple releases of SO 2 , the “Ro ot Cause” may encompass multiple primary causes.

10. “Scheduled Maintenance” shall mean work that is part of the routine work plan for the compressors located at the Facility's former gas processing plant. This work is typically planned and arranged on a set frequency, usually based on periods of time (e.g., daily, weekly or monthly) or on the operating hours of the equipment. Scheduled Maintenance shall not include work necessitated by the failure of a part of a compressor.

B. Air Pollution Control Equipment

The Main Flare shall be an automatic air

- assisted flare system.

1. The Main Flare shall be operated with a variable speed fan.

C. Emission Limit ationsMcElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 11 1. T he Permittee shall not discharge or cause the discharge of Main Flare

E missions emissions from the Main Flare into the atmosphere in excess of the following the emission limitations , based on a cumulative 365

- day rolling total

.

SO 2 NO x CO VOC

60.0 tpy 13.4 tpy 73.0 tpy 95.4 tpy

2. The Permittee shall calculate the 365

- day rolling emissions totals for SO 2 , NO
x , CO

, and VOC each day for the Main Flare.

3. The Permittee shall not use the Field Flares to circumvent the emission

limitations in Condition IX. C .1.

4. All e missions during all modes of operation (including, but not limited to, emissions during periods of startup, shutdown, or malfunction) shall be used in determining compliance with the emission limitations in Condition

IX.C.1.

D. Main Flare Operational Requirements

1. The Permittee shall install , ope rate and maintain an automatic air

- assisted flare system on the Main Flare, pursuant to the provisions of 40 CFR § 60.18(c)(5) and (f)(6).

2. The Permittee shall operate and maintain the Main Flare in compliance

with 40 CFR § 60.18(c)(l), (c)(2), (c)(3)(ii ), (c)(5), (d), (e), (f)(1) through (f)(4), and (f)(6).

3. The Main Flare shall be operated with a flame present at all times when emissions may be vented to it them

.

4. The Permittee shall comply with the following requirements for ensuring proper combustion efficiency:

(a) The Main Flare shall be operated with a variable speed fan.

(b) (a) The net heating value air assist dilution parameter (NHV dil ) shall be greater than or equal to 24 .4 BTU/ft 2

, on a daily basis, calculated in

accordance with the following equations

. If NHV dil is less than 24

BTU/ft 2 , the Permittee shall take actions as expeditiously asMcElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 12 practicable to raise NHV dil to comply with the limit. The Permittee

shall determine NHV dil in BTU/ft 2 as specified in Condition IX.E.2 of

this Permit. follows :

Equation 1: 

### DDDD = QQ vvvv × DDDDDDDD

QQ vvvv + QQ ss + QQ pppppppppppp aa + QQ pppppppppppppppppp 

### DDDD = QQ vvvv × DDDDDDDD

QQ vvvv + QQ pppppppppppp aa + QQ pppppppppppppppppp aa (Eqn 1)



### NNNNNN dd dd 

### = NNNNNN vvvv 

### × DDDD

Equation 2: (Eqn 2) 

### NNNNNN dd dd 

### = NNNNNN vvvv 

### ×

DDDD

where:

DF = Dilution factor, feet (ft).

Q vg = Volumetric flow rate of the flare vent gas, scfm.

Q
s = Cumulative volumetric flow of total steam, scfm. Q premix air = Cumulative volumetric flow of premix assist air, scfm ( Premix assist air means the portion of assist air that is introduced to the flare vent gas, whether injected or induced, prior to the flare tip )

Q perimeter air = Cumulative volumetric flow of perimeter assist air, scfm. ( Perimeter assist air means the portion of assist air introduced at the perimeter of the flare tip or above the flare tip. Perimeter assist air

includes all assist air except premix assist air. )

Diam = Diameter of the flare vent gas release stack, ft.

NHV vg = Net heating value of flare vent gas, B TU /scf.

NHV dil = Net heating value air assist dilution parameter

, BTU/ft 2

.

5. The Permittee shall also perform any necessary operations to minimize

emissions so that emissions are at or below the emi ssion limits specified in

this P ermit.

E. Monitoring

, Testing , and Emissions CalculationsMcElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 13 1. The Permittee shall use the following requirements to determine compliance with the emission limitations in Condition IX. C .1 for the Main

Flare.

(a) The Permittee shall measure and record the H 2 S concentration in the field gas at the Facility in each calendar mon th at the inlet to the Facility’ s former gas processing plant where the Main Flare is located.

(b) The Permittee shall continuously measure and record the volume of gas combusted in the Main Flare in scfm when the flare is in use

.

(c) The Permittee shall install, operate and maintain continuous monitoring systems on the Main Flare for the usage of pilot gas and purge gas (other than nitrogen or other inert gas) by the Main Flare , in standard cubic feet per minute (SCFM)

. Readings shall be taken at least once every 5 minutes and the average hourly values shall be recorded on an hourly and daily basis.

(d) (c) Each and every calendar day, the Permittee shall calculate and record the daily emissions from the Main Flare based on the last

recorded measurement o f H 2 S concentration in the field gas at the Facility and that day’s recorded volume of gas combusted in the Main

Flare.

(e) (d) Each and every calendar day, t he Permittee shall calculate the 365

- day rolling total of emissions of SO 2 , NO
x , CO

, and VOC for the Ma in

Flare , using best available data and good engineering practices

. . Each

365

- day rolling total s hall be calculated using data from the previous 365 days

. The Permittee shall maintain all records of actual operating

data and calculations.

(f) (e) If the Permittee is unable to measure the volume of gas combusted in the Main Flare on any day, the volume of gas for that day shall be deemed to be equal to the daily average volume of gas combusted in the Main Flare based on the previous 12 months’ emiss ions data. However, the use of this daily average as substitute data neither relieves nor excuses the Permittee from complying with the sampling, data collection, and monitoring requirements.

2. Determination of Net Heating Value Air Assist Dilution Parame ter

(a) Flare vent gas and air assist flowrate monitoringMcElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 14 (1) The Permittee shall use one or more of the following

m ethod s requirements to monitor flare v ent gas flowrate or comply with Condition IX.E.2.(a)(3) of this PSD Permit . In addition, the Permittee shall us e a monitoring system capable of correcting any such measured flow rates to standard conditions, as specified in Condition IX.E.2.(a)(4).

(a) C ontinuously m onitor and record the volume of gas

combusted in the Main Flare in scfm per Condition IX.E.1.(b) of this PSD Permit ; or

(b) Install, operat e , and maintain a m ass flow monitor and

determine volumetric flow rate of flare vent gas using

E quation 3 below to convert mas s flow rates to volumetric

flow rate. For the flare vent gas, molecular weight must be determined using compositional analysis

.

Equation 3 : 

### QQ
vvvv 

### = QQ
mmmm 

### × 385

. 3

MMMMMM

Where: Q vol = Volumetric flow rate, standard cubic feet per second. Q
mass = Mass flow rate, pounds per second.

385.3 = Conversion factor, standard cubic feet per pound

mole. MWt = Molecular weight of the gas at the flow monitoring location, pounds per pound

- mole.

(2) compliance with the operating limitations in Condition IX.D.4

for the Main Flare. The Permittee shall use one or more of the following methods to m onitor assist air flowrate or comply

with Condition IX.E.2.(a)(3) of this PSD Permit . In addition,

the Permittee shall us e a monitoring system capable of correcting any such measured flow rates to standard conditions, as specified in Condition IX.E.2.(a)(4).McElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 15 (a) Monitor the fan speed or power, and use fan curves and appropriate engineering calculations to determine assist air

fl ow rates; or

(b) I nstall, operate, calibrate, and maintain a monitoring system capable of continuously measuring, calculating, and recording the volumetric flow rate of assist air used with

the flare. If pre mix assist air and perimeter assist air are both us ed, install, operate, calibrate, and maintain a monitoring system capable of separately measuring, calculating, and recording the volumetric flow rate of premix assist air and perimeter assist air used with the flare;

or

(c) Install, operat e
, calibrate, and maintain a m ass flow

monitor and determin e the volumetric flow rate of assist air using E quation 3 above to convert mass flow rates to

volumetric flow rate (u s e a molecular weight of 29 pounds per pound

- mole for assist air ).

calculate and record the (3) Conti nuous pressure/temperature monitoring system(s) (i.e., at least once every 15

- minutes) and appropriate engineering calculations may be used in lieu of a volumetric flow monitoring systems provided the molecular weight of the gas is

known. For assist air, use a molecular weight of 29 pounds per pound

- mole. For flare vent gas, molecular weight must be determined using compositional analysis per Condition IX.E.2.(b) of this PSD Permit

.

(4) The flow rate monitoring systems must be able to correct for

the temperature and pressure of the system and output parameters in standard conditions (i .e., a temperature of 20°C (68°F) and a pressure of 1 atmosphere).

(b) The Permittee shall use one or more of the following methods to

monitor the net heating value of the f lare vent gas.

(1) Each month, measure and record the concentration of individual components in the flare vent gas at the Facility in each calendar month at the inlet to the Facility’s former gas processing plant where the Main Flare is located and use thisMcElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 16 i nformation to calculate NHV vg using Equation 4 in Condition IX.E.2.(c) of this PSD permit; or

(2) Each month, measure and record with a calorimeter the net heating value of the flare vent gas at standard conditions at the Facility in each calendar month at th e inlet to the Facility’s former gas processing plant where the Main Flare is located ; or

(3) The owner or operator may elect to use a different monitoring

method , determined on a monthly basis, for the vent gas provided the composition or NHV vg are determined consistent with good engineering practices

.McElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 17 (c) Each month

, t he Permittee shall determine the net heating value of the flare vent gas (NHV vg ) based on compositional analysis performed per Condition IX.E.2.(b) (1) of this PSD Permit usin g Equati on 4 below, by direct measurement of the net heating value of the flare vent gas at standard conditions as specified in Condition IX.E.2.(b)(2) of this PSD

Permit

, or as allowed by Condition IX.E.2.(b)(3) of this PSD Permit

.

Equation 4 : 

### NNNNNN vvvv 

### = �

xx nn

= 1 

### NNNNNN

Where:

NHV vg = Net heating value of flare vent gas, BTU/scf.

i = Individual component in flare vent gas.

n = Number of components in flare vent gas.

x i = Concentration of component i in flare vent gas, volume fraction.

NHV i = Net heating value of component i a ccording to T able 1

below , Btu/scf. If the component is not specified in Table

1 below , the heats of combustion may be determined using any published values where the net enthalpy per mole of offgas is based on combust ion at 25°C and 1 atmosphere (or constant pressure) with offgas water in the gaseous state, but the standard temperature for determining the volume corresponding to one mole of vent gas is 20°C.McElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 18 Table 1

— Individual Component Properties

Component Molecular

Formula MW i ( pounds per pound

- mol e ) NHV i ( British thermal units

per standard cubic foot ) Acetylene C 2 H 2 26.04 1,404

Benzene C 6 H 6 78.11 3,591
1,2

- Butadiene C 4 H 6 54.09 2,794
1,3

- Butadiene C 4 H 6 54.09 2,690

iso

- Butane C 4 H 10 58.12 2,957

n

- Butane C 4 H 10 58.12 2,968

cis

- Butene C 4 H 8 56.11 2,830

iso

- Butene C 4 H 8 56.11 2,928

trans

- Butene C 4 H 8 56.11 2,826

Carbon Dioxide CO 2 44.01 0

Carbon Monoxide CO 28.01 316 Cyclopropane C 3 H 6 42.08 2,185

Ethane C 2 H 6 30.07 1,595 Ethylene C 2 H 4 28.05 1,477 Hydrogen H 2 2.02 274 Hydrogen Sulfide H 2 S 34.08 587

Methane CH 4 16.04 896 Methyl

- Acetylene C 3 H 4 40.06 2,088 Nitrogen N 2 28.01 0 Oxygen O 2 32.00 0
Pentane+ (C5+) C 5 H 12 72.15 3,655 Propadiene C 3 H 4 40.06 2,066 Propane C 3 H 8 44.10 2,281 Propylene C 3 H 6 42.08 2,150

Water H 2 O 18.02 0

(g) (d) Each and every calendar day, t he Permittee shall determine the net heating value air assist dilution parameter ( NHV dil ) based on the f lare

vent gas flowrates per Condition IX.E.2(a)(1)

, air assist flowrate s per Condition IX.E.2(a)(2)

, and NHV vg per Condition IX.E.2 (b) and (c) of this PSD Permit, and using the equations in Condition IX.D.4 of this

PSD Permit of the field gas being combusted in the Main Flare as follows

.

(h) The Permittee shall continuously measure and record the following in

the Main Flare:McElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 19 (1) The volume of field gas combusted; (2) The volume of perimeter assist air used; and (3) (1) If pre

- mix assist air is used, the volume of premix assist air

used

.

(i) The flow rate monitoring systems must be corrected for the temperature and pressure in standard conditions (i.e., a temperature of 20 °C [68°F] and a pressure of 1 atm).

(j) The Permittee shall automatically supply supplemental fuel to the Main Flare if the field gas does not have sufficient heating value.

(k) Continuous pressure/temperature monitoring system(s) and appropriate engineering calculations may be used in lieu of a continuous volumetric flow monitoring systems provided the molecular weight of the gas is known. For assist air, use a molecular weight of 29 pounds per pound

- mole. For flare vent gas, molecular weight must be determined using compositional analysis.

(l) The Permittee shall install a monitoring system capable of calculating and recording the net heating value air assist dilution parameter of the field gas bei ng combusted in the Main Flare in sixty

- minute averages, rolled every five minutes.

(m) The Permittee shall determine the net heating value of flare vent gas (NHV vg ) using 40 CFR 60.18(f)(3).

2. 3. The Permittee shall continuously monitor the Mai n Flare for the presence of a flare pilot flame using a device (including, but not limited to, a thermocouple , ultraviolet beam sensor, or infrared sensor) capable of detecting that the pilot any other equivalent device to detect the presence of

a flame is present

. , which monitoring shall be conducted in accordance with 40 CFR 60.18(f)(2) . The heat sensing monitoring device shall be operated at all times. The Main Flare shall be equipped with an alarm that

informs Facility operators of any period when a pilot flame is not present in the flare and no gas shall be sent to the flare until a pilot flame is

restored.

3. 4. The Permittee shall operate the Main Flare with no visible emissions, except for periods not to exceed a total of 5 minutes during any 2

conse cutive hours. EPA Test Method 22 in Appendix A of 40 CFR Part 60 shall be used to determine the compliance of flares with the visibleMcElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 20 emission provisions. The observation period is 2 hours and shall be used according to Method 22. The Permittee shall pe rform monthly visible emissions tests during a flaring event using Method 22.

5. If applicable, t he Permittee shall follow the calibration and quality control requirements below for any corresponding continuous parameter measurement systems (CPMS) if used a t the Facility to comply with the requirements in Condition IX.D or IX.E of this PSD Permit.

(a) For flare vent gas volumetric flowrates , the following requirements apply:

Minimum accuracy requirements Calibration requirements

±20 percent of flow rate at velocities ranging from 0.03 to 0.3 meters per second (0.1 to 1 feet per second) ±5 percent of flow rate at velocities greater than 0.3 meters per second (1 feet per second) Conduct a flow sensor calibration check at least biennially (every two years); c onduct a calibration check following any period of more than 24 hours throughout which the flow rate exceeded the manufacturer's specified maximum rated flow rate or install a new flow sensor.

At least quarterly, inspect all components for leakage, unless the

CPMS has a redundant flow sensor.

Record the results of each calibration check and inspection.

Locate the flow sensor(s) and other necessary equipment (such as straightening vanes) in a position that provides representative flow; reduce swirling flow or abnormal velocity distributions due to upstream and downstream disturbances.

(b) For f low rate and all flows o ther than the flare vent gas, the following requirements apply:

Minimum accuracy requirements Calibration requirements

±5 percent over the normal range of flow measured or 1.9 liters per minute (0.5 gallons per minute), whichever is greater, for liquid flow Conduct a flow sensor calibration check at least biennially (every two years); conduct a calibration check following any period of more t han 24 hours throughout which the flow rate exceeded the manufacturer's specified maximum rated flow rate or install a new flow sensor.

±5 percent over the normal range of flow measured or 280 liters per minute (10 cubic feet per minute), whichever is

gre ater, for gas flow At least quarterly, inspect all components for leakage, unless the

CPMS has a redundant flow sensor.

±5 percent over the normal range

measured for mass flow Record the results of each calibration check and inspection

.McElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 21 Locate the flow s ensor(s) and other necessary equipment (such as straightening vanes) in a position that provides representative flow; reduce swirling flow or abnormal velocity distributions due to upstream and downstream disturbances.

(c) For net heating v alue determinations by c alorimeter , the following requirements apply:

Minimum accuracy requirements Calibration requirements

±2 percent of span Specify calibration requirements in your site specific CPMS monitoring plan. Calibration requirements should follow

manufacturer's recommendations at a minimum.

Temperature control (heated and/or cooled as necessary) the sampling

system to ensure proper year

- round operation.

Where feasible, select a sampling location at least two equivalent

diameters downstream from and 0.5 equivalent diameters upstream from the nearest disturbance. Select the sampling location at least two equivalent duct diameters from the nearest control device, point of pollutant generation, air in

- leakages, or other point at which a change in the pollutant concentration or emission rate occurs.

(d) For net heating value determinations by g as c hromatograph , the following requirements apply:

Minimum accuracy requirements Calibration requirements

As specified in Performance Specification 9 of 40 CFR part 60, appendix B Follow the procedure in Performance Specification 9 of 40 CFR part 60, appendix B, except that a single weekly mid

- level calibration check can be used (rather than triplicate analysis), the multi

- point calibration can be conducted quarterly (rather than monthly), and the sampling line temperature must be maintained at a minimum temperature of 60 °C (rather than 120 °C).

(e) T he following requirements apply for temperature monitoring systems :

Minimum accuracy requirements Calibration requirements

±1 percent over the normal range of temperature measured, expressed in degrees Celsius (C), or 2.8 degrees C, whichever is greater Conduct calibration checks at least annually; conduct calibration

checks following any period of more than 24 hours throughout which the temperature exceeded the manufacturer's specified maximum rated temperature or install a new temperature sensor.McElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 22 At least quarterly, inspect all components for integrity and all

electrical co nnections for continuity, oxidation, and galvanic corrosion, unless the CPMS has a redundant temperature sensor.

Record the results of each calibration check and inspection.

Locate the temperature sensor in a position that provides a representative temperature; shield the temperature sensor system from electromagnetic interference and chemical contaminants.

(f) T he following requirements apply for pressure monitoring systems :

Minimum accuracy requirements Calibration requirements

±5 percent over the normal operating range or 0.12 kilopascals (0.5 inches of water column), whichever is greater Review pressure sensor readings at least once a week for straightline (unchanging) pressure and perform corrective action to ensure proper

pressure sensor oper ation if blockage is indicated.

Using an instrument recommended by the sensor's manufacturer, check gauge calibration and transducer calibration annually; conduct calibration checks following any period of more than 24 hours throughout which the pressure exceeded the manufacturer's specified maximum rated pressure or install a new pressure sensor.

At least quarterly, inspect all components for integrity, all electrical connections for continuity, and all mechanical connections for leakage, unless the CPMS has a redundant pressure sensor.

Record the results of each calibration check and inspection.

Locate the pressure sensor(s) in a position that provides a representative measurement of the pressure and minimizes or eliminates pulsating pressure, vibration, and internal and external

corrosion.

F. Operation and Maintenance of Main Flare and Compressors

1. The Permittee shall at all times and to the extent practicable, including during periods of startup, shutdown, m alfunction Malfunction , CO 2 Breakthrough, Scheduled Maintenance, or unscheduled maintenance of the Facility’s compressors, operate and maintain the compressor station equipment and Main Flare in a manner consistent with good air pollution control practices for minimizing emissions.

2. The Permittee shall comply with the provisions of the Operations and

Maintenance Plan in Appendix A of this PSD Permit

. The Permittee ’ sMcElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 23 failure to comply with any requirement of the Operations and Maintenance

Plan shall constitute a violation.

3. The Permi ttee shall follow the procedures for the inspection of the Facility ’ s compressors and associated equipment as set forth in the Life Cycle Maintenance Plan of in the Operations and Maintenance Plan in Appendix A of this PSD Permit , and shall maintain inspection logs at the Facility documenting that these inspections have been conducted.

4. The Permittee shall maintain daily records at the Facility regarding operation of the Facility ’ s compressors on a Daily Plant Reading Form in

th e Operations and Maintenance Plan in Appendix A of this PSD Permit

.

5. The Permittee shall maintain a supply of designated spare parts for the Facility’s compressors and associated equipment that includes all of the equipment on the Spare Parts List in the O perations and Maintenance Plan in Appendix A of this PSD Permit.

6. After using equipment on its Spare Parts List, the Permittee shall replace such equipment as expeditiously as possible. The Permittee shall place a purchase order for such equipment within 45 days after it is used.

7. The Permittee shall conduct training of Facility operators in accordance with the Training Program for Plant Operators in Section 5 IV of the Operations and Maintenance Plan in Appendix A of this PSD Permit. The

Permittee shal l maintain records documenting that the training has been

conducted.

8. The Permittee shall retain copies of inspection logs and other records required by S ection IX. F (Operations and Maintenance of Main Flare and Compressors) of this PSD Permit

.

9. The Pe rmittee shall maintain inspection, maintenance and repair log(s) or

other similar records and identify any occasion when the Permittee was unable to carry out its established maintenance procedures, with explanation.

10. Root Cause Analysis The Operations and Maintenance Plan in Appendix

A of this PSD Permit shall be updated periodically to account for changes in the operation of the Main F lare, but the plan need be resubmitted to the EPA only if the owner or operator adds new equipment or removes existing equ ipment listed in th is PSD P ermit. If such revision is needed,McElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 24 Resolute shall request a permit amendment (Attn: AIR

- 3) . The owner or operator must comply with the updated plan as submitted.

G. Flare Minimization for the Main Flare

1. Flare Minimization Plan

(a) The Permittee shall d evelop and implement a written Flare Minimization Plan (FMP) for the Main Flare that contains information about the operation of the flare to minimize Flaring Incidents

. At minimum, t he FMP must include all of the following informatio n:

(1) A listing of all process units and ancillar y equipment connected

to the flare.

(a) Flare design parameters including:

(i) A general description of the flare, including whether it is a ground flare or elevated (including height); (ii) Information regarding design capacity; (iii) General description of flare tip (date installed, manufacturer, nominal and effective tip diameter, tip drawing); (iv) A description of the assist system and an indication of whether the fan/blower is single speed

, multi

- fixed speed (e.g., high, mediu m, and low speeds)

, or variable speeds; and (v) The flame detection system and pilot ignition system.

(2) Detailed description of the manufacturer’s specifications, including, but not limited to, make, model, type, range, precision, accuracy, calibration, maintenance and quality assurance procedures.

(3) A simple process flow diagram of the flare system illustrating all connections to the flare including all pipelines, process units, compressors and other ancillary equipment that vent to

the flare.

(4) A descript ion of the locations of all associated monitoring and of the methods for monitoring flow rate to the flare (including a detailed description of the manufacturer’s specifications forMcElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 25 each flow monitoring system including but not limited to make, model, type , range, precision, accuracy, calibration, maintenance, and quality assurance procedures for flare gas monitoring devices).

(5) A description of the data recording, collection and management for the flare monitoring system.

(6) An assessment of whether discharge s to the flare from these process units and ancillary equipment can be minimized or prevented during periods of upsets, malfunctions, or emergency releases.

(7) A description of the method to alert personnel designated to collect samples that a F lare I ncident has started.

(b) The Permittee shall d evelop and implement a written FMP no later than three ( 3 ) years after the final PSD permit amendment becomes effective pursuant to 40 CFR 124.15(b).

(c) The FMP shall be updated periodically to account for changes in the

o peration of the Main F lare, such as new connections to the Main

F lare, at least once every five (5) years since the previous update of the plan . The owner or operator need not resubmit the plan to the EPA

unless the owner or operator alters the design cap acity of the Main

F lare. The owner or operator must comply with the updated plan as

submitted.

1. No later than 72 hours after an event first qualifies as a Flaring Incident, the Permittee shall notify by telephone, at (415) 947

- 8700 , the Manager of

the Air/TRI Enforcement Office, Enforcement Division of EPA Region IX, of su ch Flaring Incident. Telephone notification shall be followed by a detailed written notification to EPA, at the address in Condition X. C of this PSD Permit, made within seven (7) work ing days after the event first qualifies as a Flaring Incident.

2. Root Cause Analysis

(a) For a Flaring Incident caused by Scheduled Maintenance or a CO 2 Breakthrough, the Permittee shall submit a report to the EPA, at the

address in Condition X. C of this P SD Permit, no later than sixty (60) days following the end of such a Flaring Incident that sets forth the following information listed below. Except for those Flaring IncidentsMcElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 26 caused by Scheduled Maintenance or a CO 2 Breakthrough, the Permittee shall conduct a Root Cause Analysis in accordance with the Root Cause Failure Analysis Program in Appendix B of this PSD

Permit to evaluate the cause of each Flaring Incident and shall submit

a report to the EPA, at the address in Condition X

. C of this PSD Permit, no later than sixty (60) days following the end of a Flaring Incident, that sets forth all of the following:

(1) The date and time that the Flaring Incident started and ended. To the extent that the Flaring Incident involved multiple

releases either within a twenty

- four ( 24

- ) hour period or within subsequent, contiguous, non

- overlapping twenty

- four ( 24

- ) hour periods, the Permittee shall set forth the starting and ending dates and times of each release;

(2) An estimate of the quantity of SO 2 that was emitted and the calculations that were used to determine that quantity;

(3) The steps, if any, that the Permittee took to limit the duration and/or quantity of SO 2 emissions associated with the Flaring Incident;

(4) Except for those Flaring Incident s caused by Scheduled

Maintenance or a CO 2 Breakthrough, a detailed analysis that sets forth the Root Cause and all contributing causes of that Flaring Incident, to the extent determinable; however, if a Flaring Incident is caused by Scheduled Maintenance or CO 2 Breakthrough, then the Permittee need only identify the Root

Cause as Scheduled Maintenance or CO 2 Breakthrough (whichever is applicable), and either (i) describe the nature of the work done for Scheduled Maintenance or (ii) identify the specific we lls that most likely experienced the CO 2 Breakthrough;

(5) An analysis of the measures, including possible design, operational, and maintenance changes, that are available to reduce the likelihood of a recurrence of a Flaring Incident resulting from the same Root Cause or contributing causes in

the future. If the Permittee concludes that corrective action(s) is (are) required under Section IX. G.3 H (Corrective Action) of

this PSD Permit , the report shall include a description of the action(s) and, if not already completed, a schedule for its (their)McElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 27 implementation, including proposed commencement and completion dates. If the Permittee concludes that corrective action is not required under Section IX. G.3 H (Corrective Action) of this PSD Permit, the report shall explain the basis for that conclusion;

(6) To the extent that investigations of the causes and/or possible corrective actions still are under way on the due date of the report, a statement of the anticipated date by which a follow

- up report fully conforming to the requirements of Conditions

IX.G.2

. (a)(4) .d and (5) IX.G.2.e of this PSD Permit will be

submitted

. Nothing in this Permit Condition shall be deemed to excuse the Permittee from its investigation, notification, reporting, and corrective action obligat ions in this PSD Permit for any Flaring I ncident that occurs after the Flaring Incident

for which the Permittee has requested an extension of time

under this Permit Condition

.

(7) To the extent that completion of the implementation of corrective action(s), if any, is not finalized at the time of the submission of the report required under this Permit Condition

, then, by no later than thirty (30) days after completion of the implementation of corrective action(s), the Permittee shall submit a report identifying the corrective action(s) taken and

the d ates of commencement and completion of implementation.

(b) The Root Cause Failure Analysis Program in Appendix B of this PSD

Permit shall be updated periodically to account for changes in the operation of the Main F lare, but the plan need be resubmitted to the EPA only if the owner or operator adds new equipment or removes existing equipment listed in the permit. If such revision is needed,

Resolute shall request a permit amendment (Attn: AIR

- 3) . The owner or operator must comply with the updated Root Caus e Failure Analysis Program as submitted.

(c) No later than 72 hours after an event first qualifies as a Flaring Incident, the Permittee shall notify by electronic mail , at AEO_R9@epa.gov , the Manager of the Air/TRI Enforcement Office,

Enforcement Division

, EP A Region 9 , of such Flaring Incident

. Telephone notification shall be followed by a detailed written

notification to the EPA, at the address in Condition X.C of this PSDMcElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 28 Permit, made within seven (7) working days after the event first qualifies as a Flari ng Incident.

2. 3. Corrective Action

In response to any Flaring Incident, the Permittee shall take, as expeditiously as practicable, such interim and/or long

- term corrective actions, if any, as are consistent with good engineering practice to

minimize the likelihood of a recurrence of the Root Cause and all contributing causes of that Flaring Incident.

H. Compliance Reporting

1. Within thirty (30) days following the end of each calendar semiannual period (i.e., January 1 to June 30, and July 1 to December 31), the

Permittee shall submit to the EPA a semiannual report.

2. All semiannual reports shall be signed and affirmed by a responsible official, and bearing the certification statement as follows:

“I certify under penalty of law that I have examined and am familiar with

the information submitted in this document and all attachments and that this document and its attachments were prepared either by me personally or under my direction or supervision in a manner designed to ensure that qualified and knowledgeab le personnel properly gathered and presented the information contained therein. I further certify, based on my personal knowledge or on my inquiry of those individuals immediately responsible for obtaining the information, that the information is true, ac curate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing and willful submission of a materially false statement.”

3. All semiannual reports shall include the following information:

(a) A list of the rolling 365

- day cumulative Main Flare

E missions emissions for each day in that semiannual period ;

(b) A list of the NHV dil in BTU/ft 2 determined for each day in that semiannual period.McElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 29 (b) (c) A list of each day in the semiannual period when the emissions limits that apply to the Main Flare were exceeded and, for each such day, the limit(s) exceeded and the amount(s) of excess emissions;

(c) (d) A list of all emissions for the semiannual period that th e Permittee claims are attributable to Malfunctions;

(d) (e) A list of all emissions for the semiannual period that may be

attributable to CO 2 Breakthroughs, Scheduled Maintenance, or unscheduled maintenance of the Facility ’ s compressors;

(e) (f) The date(s) and time( s) during the semiannual period when the thermocouple or flow meter associated with the Main Flare was inoperative;

(f) (g) The date(s) and time(s) during the semiannual period when the

Permittee failed to measure or record the H 2 S concentration in the field

gas at the Facility or failed to continuously measure or record the volume of gas combusted in the Main Flare;

(g) (h) A certification that during the semiannual period the Permittee operated and maintained the compressor station equipment and Main

Flare in a manne r consistent with good air pollution control practices for minimizing emissions, and performed all of the obligations (including, but not limited to, inspection and training obligations)

contained in the Operations and Maintenance Plan in Appendix A of

thi s PSD Permit ;

(h) (i) A certification that the Field Flares have not been used to circumvent the emission limits that apply to the Main Flare;

(i) (j) A list of total emissions from the Field Flares and the reason for Flaring ; and

(j) (k) Any and all reports generated from the FMP, and root cause analysis and corrective action program of Condition Conditions IX. G

and IX.H of this PSD Permit

.

I. Recordkeeping RequirementsMcElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 30 1. The Permittee shall maintain a file of all records, data, measurements, reports, and documents related to operation of the Facility. All records

shall be in a permanent form suitable for inspection.

2. The Permittee shall retain the following records at the facility for a period

of at least five (5) years from the date of monitoring, sampling, measurement, or reporting. All applicable records shall be maintained at the nearest manned facility and shall be readily accessible.

(a) Each 365

- day rolling total for SO 2 , NO
x , CO

, and VOC emissions ;

(b) Daily calculations of NHV dil in BTU/ft 2 , and the methods used to

determine NHV dil in Condition IX.E.2 of this PSD Permit.

(b) (c) Emissions calculations of SO 2 , NO
x , CO

, and VOC for the Main

Flare , which shall include the e mission factors , operating data and

other supporting documentation that the Permittee use d to calculate emissions of each pollutant ;

(c) (d) Monthly H 2 S concentration in the field gas at the Facility;

(d) (e) Daily total volume of gas combusted in the Main Flare;

(e) (f) Gas throughput;

(f) (g) Records of gas analyses and testing;

(g) (h) Records of flare design for the Main Flare in accordance with 40 CFR 60.18 (including whether the flare is steam

- assisted, air

- assisted,

or non

- assisted);

(h) (i) Semiannual reports required in Section IX. H I (Compliance Reporting), of this PSD Permit ;

(i) (j) A written log of the monthly inspections of the Main Flare containing the following information for ea ch inspection: (i) the date and time of the inspection, and the name of the observer; (ii) a description of any corrective actions taken and repairs made; and (iii) the date(s) of corrective actions and repairs;

(j) (k) Visible emission readings, heat content determinations, flowrate measurements, and exit velocity determinations made ;McElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 31 (k) (l) Pe riods when the pilot flame is absent or spark igniter(s) is inoperable ;

(l) (m) A ny and al l reports generated from the root cause analysis and corrective action program, which shall include the following :

(1) Date, time and duration of flaring ;

(2) Description of the event, including the flare(s) involved in the event and a discussion of the cause(s) and probable cause(s) of

the event ;

(3) Confirmation that the flare(s) functioned properly, i.e., a flame was present and any visible emissions that occurred were in compliance with 40 CFR 60.18(f)(1) ;

(4) Corrective actions taken during the event ; and

(5) A description of any actions taken to prevent or reduce the

likelihood of similar future occurrences.

(m) (n) I nspection, maintenance and repair log(s) o r other similar records ; and

(n) (o) Any other records and reports required by this PSD permit.

X. AGENCY NOTIFICATION

A. Permit Applications & Permit

- Related Requests

.

The owner or operator shall submit permit applications, permit amendments, and other applicable permit information, which includes but not limited to installation of control equipment, replacement of an emissions unit, and changes that contravene permit terms, to:

D irector, Air Division (Attn: AIR

- 3) U. S. Environmental Protection Agency Region 9

75 Hawthorne Street San Francisco, CA 94105McElmo Creek Unit Oil Production Facility Proposed Amended PSD Permit No. NU 05

- 01 Septe mber 30, 2016 October 2014 32 B. Submittals to Navajo Nation Environmental Protection Agency

.

The owner or operator shall submit copies of a ll correspondence required by this

PSD Permit to:

Navajo Nation Environmental Protection Agency Air Quality Control Program and Operating Permits Program

P

. O

. Box 529 Fort Defiance, AZ 86504

C. Compliance Reporting

.

Unless otherwise directed by the EPA or this PSD P ermit, the owner or operator shall submit a copy of all test plans, reports, certifications, notifications, and other information pertaining to compliance with this PSD Permit to the following address. All notices and submissions shall be sent by certifie d mail, express mail, or similar overnight mail delivery with return receipt requested and addressed to :

Director, Enforcement Division (Attn: ENF

- 2

- 1) U.S. Environmental Protection Agency, Region 9 IX

75 Hawthorne Street San Francisco, California 94105

All notices and submission made in accordance to Condition X.C .1 shall be deemed submitted on the date postmarked. All notices and submission s made in

accordance to Condition X. C .1 shall be signed and affirmed by a responsible official, and bearing the certification statement as follows:

“I certify under penalty of law that I have examined and am familiar with the

information submitted in this document and all attachments and that this document and its attachments were prepared either by me personally or under my direction or supervision in a manner designed to ensure that qualified and knowledgeable personnel properly gathered and presented the information

contained therein. I fur ther certify, based on my personal knowledge or on my inquiry of those individuals immediately responsible for obtaining the information, that the information is true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing and willful submission of a materially false statement.”