# »;tt**~~** 

# , -. BISON

ENGINEERING, INC.

September 29, 2011

Ms. Kathleen Paser EPA Region 8 Tribal Air Coordinator U.S. EPA, Region 8 1595 Wynkoop Avenue, 8P-AR Denver, CO 80202-1129 140011''' AVENUE' HELENA, MT 59601 • 406-442-5768

FAX:**406~449·6653** • E-MAIL: bison@bison-eng.com • www.bison-eng.com



### Duplicate submittal provided via e-mail to: paser.kathleen@epa.gov

RE: Synthetic Minor Permit Application for the FBIR Iron Woman & 

### Yellow Wolf Pad

Dear Ms. Paser:

Bison Engineering, Inc. (Bison), as contracted by XTO Energy, Inc. (XTO), is submitting

a Synthetic Minor Permit Application for the Iron Woman 

### & Yellow Wolf Pad. This application is being submitted in accordance with the requirements of the August 29, 2011 Consent Agreement, regarding compliance with the Federal Minor New Source Review Rule.

If the Agency has any questions or concerns, please contact me (406.442.5768 or bret@bison-eng.com). I will be pleased to assist you.
Sincerely, BISON ENGINEERING, INC.

Bret Gallo Project Engineer

Attachment

cc: John McMichael, XTO Energy, Inc. Joe Gillies Jr. Environmental Director, Environmental Division, 204 W. Main, New Town, NO 58763-9404 Tex hall, Chairman Three Affiliated Tribes, 404Frontage Road, New Town, NO 58763-9404

An Employee Owned Company

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


## Check List – Application for New Construction (Form NEW) **Please check all that apply to show how you are using this form**

**Proposed Construction of a New Facility Proposed Construction of New Equipment at an Existing Facility**  **Proposed Modification of an Existing Facility Other – Please Explain**  **Use of this information request form is voluntary and not yet approved by the Office of Management and Budget.**  The following is a check list of the type of information that Region 8 will use to process information on your proposed project. While submittal of this form is not required, it does offer details on the information we will use to complete your requested approval and providing the information requested may help expedite the process. Use of application forms for this program is currently under Office of Management and Budget review and these information request forms will be replaced/updated after that review is completed.

**Please submit information to following two entities:**

Minor NSR Permitting Coordinator U.S. EPA, Region 8 1595 Wynkoop Avenue, 8P-AR Denver, CO 80202-1129 The Tribal Environmental Contact for the specific reservation:

If you need assistance in identifying the appropriate Tribal Environmental Contact and address, please contact the EPA Region 8 Tribal Air Coordinator:

Alexis North, EPA Region 8 Tribal Air Coordinator 303-312-7005 north.alexis@epa.gov



### A. GENERAL FACILITY INFORMATION 1. (a) **Company Name** XTO Energy, Inc.

(b) **Operator Name** XTO Energy, Inc 2. **Facility Name** FBIR Iron Woman/Yellow Wolf Pad

3. Type of Operation Oil and Gas Production 4. Portable Source? Yes No 5. Temporary Source? Yes No
6. NAICS Code 213111 7. SIC Code 1311 8. Physical Address: 810 Houston St. Ft Worth, TX 76102 (main office) 9. Reservation* FBIR 10. County* Dunn 11a. Latitude* 47° 39' 35.978" N 11b. Longitude* 102° 23' 18.661" W

12a. Quarter Quarter Section * NENW 12b. Section* 10 12c. Township* 148N 12d. Range* 92W

### B. PREVIOUS PERMIT ACTIONS (Provide information in this format for each permit that has been issued to this facility. Provide as an attach ment if additional space is necessary)

This section of the permit application is not appli cable. This application is for a new facility for which no previous permit actions have been taken.

Facility Name on the Permit N/A

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

Date of the Permit Action N/A

### C. CONTACT INFORMATION **Company Contact :**  John McMichael **Title:** Environmental Engineer
**Mailing Address :**  810 Houston St. Ft Worth, TX 76102

**Email Address :**  John_McMichael@xtoenergy.com

**Telep ho**  **ne Number** : (817) 885-3782 **Facsimile Number**  **:** (817) 885-2683

**Operator Contact**  (if different from company contact): Same as above Title

Mailing Address

Email Address

Telephone Number Facsimile Number

**Facility Contact**  **:** Same as above Title

Mailing Address

Email Address

Telephone Number Facsimile Number

**Compliance Contact:** Same as above Title

Mailing Address

Email Address

Telephone Number Facsimile Number

### D. ATTACHMENTS **Include all of the following information** (see the attached instructions)

 **FORM SYNMIN -** New Source Review Synthetic Minor Limit Request For m, if synthetic minor limits are being requested.

 Narrative description of the proposed production pr ocesses. 

### This description should follow the flow of the process flow diagram to be submitted with this application.

 Process flow chart identifying all proposed process ing, combustion, handling, storage, and emission co ntrol equipment.

 

### A list and descriptions of all proposed emission un its and air pollution-generating activities.

 Type and quantity of fuels, including sulfur conten t of fuels, proposed to be used on a daily, annual and maximum hourly basis.

 Type and quantity of raw materials used or final pr oduct produced proposed to be used on a daily, annu al and maximum hourly basis.

 Proposed operating schedule, including number of ho urs per day, number of days per week and number of weeks per year.

 A list and description of all proposed emission controls, control efficien cies, emission limits, and monitoring for each emission unit and air pollution generating activity.

 **Criteria Pollutant Emissions -** Estimates of Current Actual Emissions, Current Allo wable Emissions, PostChange Uncontrolled Emissions, and Post-Change Allo wable Emissions for the following air pollutants: particulate matter, PM 10 , PM 2.5 , sulfur oxides (SOx), nitrogen oxides (NOx), carbo n monoxide (CO), volatile organic compound (VOC), lead (Pb) and lead compound s, fluorides (gaseous and particulate), sulfuric ac id mist (H 2 SO 4 ), hydrogen sulfide (H 2 S), total reduced sulfur (TRS) and reduced sulfur c ompounds, including all calculations for the estimates.

 These estimates are to be made for each emission un it, emission generating activity, and the project/f acility in total.

 **Modeling – Air Quality Impact Analysis (AQIA)**

 **ESA (Endangered Species Act)**

 **NHPA (National Historic Preservation Act)**

### 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 of this form, as appropriate for the use specified at the top of the form.

**E(i) – Proposed New Facility Pollutant**  **Potential Emissions (tpy)**  **Proposed Allowable Emissions**  **(tpy)** PM - Particulate Matter PM 10 - Particulate Matter less than 10 microns in size PM 2.5 - 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 H 2 SO 4 - Sulfuric Acid Mist H 2 S - Hydrogen Sulfide TRS - Total Reduced Sulfur RSC - Reduced Sulfur Compounds **PM** 

### 5.59 5.84

**PM 10**  

### 5.59 5.84

**PM 2.5**  

### 5.59 5.84

**SO x**  

### 0.01 0.01

**NO x**  

### 87.68 92.13

**CO** 

### 189.44 213.61

**VOC** 

### 10200.51 177.40

**Pb** 

### Negligible Negligible

**Fluorides** 

### Negligible Negligible

**H 2**  **SO 4**  

### Negligible Negligible

**H 2**  **S** 

### Negligible Negligible

**TRS** 

### Negligible Negligible

**RSC** 

### Negligible Negligible

Emissions calculations must include fugitive emissi ons if the source is one the following listed sources, pursuant to CAA Section 302(j):

(a) Coal cleaning plants (with thermal dryers); (b) Kraft pulp mills; (c) Portland cement plants; (d) Primary zinc smelters; (e) Iron and steel mills; (f) Primary aluminum ore reduction plants; (g) Primary copper smelters; (h) Municipal incinerators capable of charging more than 250 tons of refuse per day; (i) Hydrofluoric, sulfuric, or nitric acid plants; (j) Petroleum refineries; (k) Lime plants; (l) Phosphate rock processing plants; (m) Coke oven batteries; (n) Sulfur recovery plants; (o) Carbon black plants (furnace process); (p) Primary lead smelters; (q) Fuel conversion plants; (r) Sintering plants; (s) Secondary metal production plants; (t) Chemical process plants (u) Fossil-fuel boilers (or combination thereof) to taling more than 250 million British thermal units per hou r heat input; (v) Petroleum storage and transfer units with a tot al storage capacity exceeding 300,000 barrels; (w) Taconite ore processing plants; (x) Glass fiber processing plants; (y) Charcoal production plants; (z) Fossil fuel-fired steam electric plants of more that 250 million British thermal units per hour heat inp ut, and (aa) Any other stationary source category which, as of August 7, 1980, is being regulated under section 11 1 or 112 of the Act.

### E(ii) – Proposed New Construction at an Existing Fa **cility or Modification of an Existing Facility**

This section of the application is not applicable. The application is for a new facility only.

**Pollutant Current**  **Actual Emissions**  **(tpy) Current**  **Allowable Emissions**  **(tpy) Post-Change**  **Potential Emissions**  **(tpy) Post-Change**  **Allowable Emissions**  **(tpy)**
**PM** 

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

**PM 10**  

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

**PM 2.5**  

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

**SO x**  

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

**NO x**  

### 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

**NH 3**  

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

**Fluorides** 

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

**H 2**  **SO 4**  

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

**H 2**  **S** 

### 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 10 - Particulate Matter less than 10 microns in size PM 2.5 - Particulate Matter less than 2.5 microns in siz e SOx - Sulfur Oxides NOx - Nitrogen Oxides CO - Carbon Monoxide VOC - Volatile Organic Compound Pb - Lead and lead compounds NH 3 - Ammonia Fluorides - Gaseous and particulates H 2 SO 4 - Sulfuric Acid Mist H 2 S - Hydrogen Sulfide TRS - Total Reduced Sulfur RSC - Reduced Sulfur CompoundsPage 7 of 15 

## Instructions

**Use of This Form**

• Proposed new construction or modifications should f irst be evaluated to determine if the change is major under the major NSR program using the procedu res at 40 CFR 52.21 (i.e., baseline actual to projected actual applicability test). If the propo sed construction does not qualify as a major under that test, then it may be subject to the requiremen ts of the minor NSR rule at 40 CFR 49.151.

**Helpful Definitions from the Federal Minor NSR Rule (40 CFR 49) –**  This is not a comprehensive list.



### • 40 CFR 49.152(d) - Modification means any physical or operational change at a sourc e that would cause an increase in the allowable emissions of the affected emissions units for any regulated NSR pollutant or that would cause the emission of any r egulated NSR pollutant not previously emitted.

The following exemptions apply:

(1) A physical or operational change does not inclu de routine maintenance, repair, or replacement.

(2) An increase in the hours of operation or in the production rate is not considered an operational change unless such increase is prohibited under any federally-enforceable permit condition or other permit condition that is enforceable as a pra ctical matter.

(3) A change in ownership at a source is not consid ered a modification.

• 40 CFR 49.152(d) - Allowable emissions means ‘‘allowable emissions’’ as defined in §52.21(b)(16), except that the allowable emissions for any emissions unit are calculated considering any emission limitations that are enfor ceable as a practical matter on the emissions unit’s potential to emit.

• 52.21(b)(16) - Allowable emissions means the emissions rate of a stationary source ca lculated using the maximum rated capacity of the source (unl ess the source is subject to federally enforceable limits which restrict the operating rat e, or hours of operation, or both) and the most stringent of the following:

(i) The applicable standards as set forth in 40 CFR parts 60 and 61;

(ii) The applicable State Implementation Plan emiss ions limitation, including those with a future compliance date; or

(iii) The emissions rate specified as a federally e nforceable permit condition, including those with a future compliance date.Page 8 of 15 

## A. General Facility Information

1. Company Name & Operator Name (if different): Pr ovide the complete company and operator names. For corporations, include divisions or subsidiary name, if any.

2. Facility Name: Provide the facility name. Plea se note that a facility is a site, place, location, etc... that may contain one or more air pollution emitting units.

3. Type of Operation: Indicate the generally accep ted name for the operation (i.e., asphalt plant, ga s station, dry cleaner, sand & gravel mining, oil and gas wellsite , tank battery, etc.).

4. Portable Source: Does the facility operate in m ore than one location? Some examples of portable s ources include asphalt batch plants and concrete batch pla nts.

5. Temporary Source: A temporary source, in gener al, would have emissions that are expected last les s than 2 years. Do you expect to cease operations within th e next 2 years?

6. NAICS Code: North American Industry Classificat ion System. The NAICS Code for your facility can b e found at the following link  North American Industry Classification System ( http://www.census.gov/epcd/naics/nsic2ndx.htm#S1 ).

7. SIC Code: Standard Industrial Classification Co de. Although the new North American Industry Classification System (NAICS) has replaced the SIC codes, much of the Clean Air Act permitting process es continue to use these codes. The SIC Code for your facility can be found at the following link  Standard Industrial Classification Code ( http://www.osha.gov/pls/imis/sic_manual.html ).

8. Physical Address: Provide the actual address o f where the facility is operating, not the mailing address. Include the State and the ZIP Code.

9. Reservation: Provide the name of the Indian re servation within which the facility is operating.

10. County: Provide the County within which the fa cility is operating.

11a & 11b. Latitude & Longitude: These are GPS ( global positioning system) coordinates. This infor mation can be provided in decimal format or degree-minute- second format.

12a – 12d. Section-Township-Range: Please provide these coordinates in 1/4 Section/Section/Township/ Range. (e.g., SW 1⁄4 , NE 1⁄4 /S36/T10N/R21E).Page 9 of 15 

## B. Current Permit Information

Provide a list of all permits that have been issued to your facility. This should include any Federal Minor New Source Review (MNSR), Prevention of Signi ficant Deterioration (PSD) or NonAttainment New Source Review (NA NSR) permits, in a ddition to the most recent Part 71 permit. The permit number must be included with each permit ide ntified.



## C. Contact Information

Please provide the information requested in full.

1. Company Contact: List the full name (last, midd le initial, first) of the owners of the facility or the company
contact.

2. Operator Contact: Provide the name of the oper ator of the facility if it is different from the co mpany contact.

3. Facility Contact: The facility contact must be the local contact authorized to receive requests f or data and information.

4. Compliance Contact: The compliance contact mus t be the local contact responsible for the facility ’s compliance with this rule. If this is the same as the Facility Contact please note this on the form.



## D. Attachments

This section lists the information needed to comple te the requested approval. This information should be accompanied by the supporting information listed on the form and described below. The information should be presented in enough detail to document ho w the facility is currently operating and/or how it is pr oposed to operate.

 **FORM SYNMIN**

If synthetic minor limits are being requested, we r ecommend that the information from checklist tiled Form SYNMIN be included with this application.

 Narrative description of the proposed production pr ocesses.

1. 

### The narrative description should follow the flow of the process flow diagram to be submitted with this application. This needs to be as compreh ensive 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 of the raw materials? Does the production process include heating, drying , the application of chemicals, etc? How will the raw materials be affected by this proc ess? What are the out puts from each step of the process (i.e., crushed ore, dry gas, water, etc...)? Etc....



### 2. The proposed operating schedule presented in terms of hours per day, days per week, and weeks per year. 3. A list of the type and quantity of fuels and/or raw materials used. Each fuel and raw material should be described in enough detail to in dicate its basic chemical components.Page 10 of 15  A process flow chart identifying all proposed proce ssing, combustion, handling, storage, and emission control equipment (include the unit identification # or code). This flow chart should illustrate the detailed narrative description requested above.



###  L 

### ist and describe all proposed units, emission units and air pollution-generating activities. At a minimum, provide the following:

1. The hourly, daily and annual maximum operating rate s for each operating unit, production process, and activity. 2. The hourly, daily and annual maximum firing rates f or each fuel and combustion equipment. 3. The capacity for storage units and the hourly, dail y and annual maximum throughput of material in the storage units. 4. Material and product handling equipment and the hou rly, daily and annual maximum throughput of material and product. 5. 

### Tank designs, tank storage capacities, hourly, dail y and annual maximum throughput of material and product.

 Type and quantity of fuels, including sulfur conten t of fuels, proposed to be used on a daily, annual and maximum hourly basis.

 Type and quantity of raw materials used or final pr oduct produced proposed to be used on a daily, annu al and maximum hourly basis.

 Proposed operating schedule, including number of ho urs per day, number of days per week and number of weeks per year.

 

### A list and description of all proposed emission controls, control efficien cies, emission limits, and monitoring for each emission unit and air pollution generating activity.



### 1. Include manufacturer specifications and guarantees for each control device.Page 11 of 15 

## Criteria Pollutant Emissions **Estimates**

 Estimates of Current Actual Emissions, Current Allo wable Emissions, Post-Change Uncontrolled Emissions, and Post-Change Allowable Emissions for the following air pollutants: particulate matter, PM 10 

### , PM 2.5 

### , sulfur oxides (SOx), nitrogen oxides (NOx), carbo n monoxide (CO), volatile organic compound (VOC), lead (Pb) and lead compound s, ammonia (NH 3 

### ), fluorides (gaseous and particulate), sulfuric acid mist (H 2 

### SO 4 

### ), hydrogen sulfide (H 2 

### S), total reduced sulfur (TRS) and reduced sulfur compounds, including all calculation s for the estimates.

1. These estimates are to be made for each emission un it, emission generating activity, in addition to total emissions.

2. The information should include all of the supportin g calculations, assumptions and references. Emission estimates must address all emi ssion units and pollutants proposed and/or affected by the limitation and be presented in short term (e.g. pounds per hour) as well as annual (tons per year) units.

3. Any emission estimates submitted to the Regional Ad ministrator must be verifiable using currently accepted engineering criteria. The following procedures are generally acceptable for estimating emissions from air pollut ion sources:

• Source-specific emission tests;

• Mass balance calculations;

• Published, verifiable emission factors that are app licable to the source. (i.e. manufacturer specifications)

• Other engineering calculations; or

• Other procedures to estimate emissions specifically approved by the Regional Administrator.

4. Guidance for estimating emissions can be found at http://www.epa.gov/ttn/chief/efpac/index.html

.

Current Actual Emissions: Current 

### actual emissions for a pollutant is expressed in tp y and generally is calculated by multiplying the actual h ourly emissions rate in pounds per hour (lbs/hr) times actual hours operated (which is the number of hours in a year) and dividing by 2,000 (which is the number of pounds in a ton).

1. For an **existing air pollution source (permitted and unperm itted)**  that operated prior to the application submittal, the current actual emissions are the actual rate of emissions for the preceding calendar year and must be calculated usin g the actual operating hours, production rates, in-place control equipment, and types of mat erials processed, stored, or combusted during the preceding calendar year. The emission es timates must be based upon actual test data or, in the absence of such data, upon procedures ac ceptable to the Regional Administrator.



### Current Allowable Emissions: Current allowable emi ssions for a pollutant is expressed in tpy and generally is calculated by multiplying the allowed hourly emissions rate in pounds per hour (lbs/hr) times allowed hours (which is the number of hours i n a year) and dividing by 2,000 (which is the number of pounds in a ton).

1. “Allowed” means the source is restricted by permit conditions that limit its emissions and are enforceable as a practical matter (i.e., allowable emissions). The allowable emissions for anyPage 12 of 15 

### emissions unit are calculated considering any emiss ions limitations that are enforceable as a practical matter on the unit’s PTE.

2. For an **existing permitted air pollution source** that operated prior to the application submittal, the current allowable emissions are the allowable rate of emissions for the preceding calendar year and mu st be calculated using the permitted operating hours, production rates, in-place control equipment, and types of materials processed, stored, or combusted during the preceding calendar year.



### 3. For an **existing air pollution source** that does not have an established allowable emissions level prior to the modification must repo rt the pre-change uncontrolled emissions.

Post-Change Potential Emissions (Potential uncontro lled emissions from proposed project): This is the maximum capacity of a source to emit a pollutan t under its physical and operational design. This is expressed in tpy and generally is calculate d by multiplying the maximum hourly emissions rate in pounds per hour (lbs/hr) times 8,760 hours (which is the number of hours in a year) and dividing by 2,000 (which is the number of pounds in a ton).

Post-Change Allowable Emissions: A source’s allowa ble emissions for a pollutant is expressed in tpy and generally is calculated by multiplying the allowed hourly emissions rate in pounds per hour (lbs/hr) times allowed hours (which is the number o f hours in a year) and dividing by 2,000 (which is the number of pounds in a ton).

1. Unless the source is restricted by permit condition s or other requirements that are enforceable as a practical matter, the post-change allowable em issions would be equivalent to post-change uncontrolled emissions. For the post-change allowa ble emissions a lower level of allowable emissions may be proposed.

2. For physical or operational changes at minor source s and for minor physical or operational changes at major sources, the total increase in all owable emissions resulting from your proposed change would be the sum of following:

• 

### For each new emissions unit that is to be added, th e emissions increase would be the potential to emit of each unit.

• 

### For each emissions unit with an allowable emissions limit that is to be changed or replaced, the emissions increase would be the allow able emissions of the emissions unit after the change or replacement minus the allowable emissions prior to the change or replacement. However, this may not be a negative v alue. If the allowable emissions of an emissions unit would be reduced as a result of the change or replacement, use zero in the calculation.

• 

### For each unpermitted emissions unit (i.e., a unit w ithout any emissions limitations before the change) that is to be changed or replaced, the emissions increase would be the allowable emissions of the unit after the change or replacement minus the potential to emit prior to the change or replacement. However, this may not be a negative value. If the allowable emissions of an emissions unit would be r educed as a result of the change or replacement, use zero in the calculation.Page 13 of 15 

###  

## Modeling Analysis

Do I need to do a modeling analysis?

The Federal Minor New Source Review Regulations at 40 CFR 49.159(d) requires that a modeling analysis (AQIA) of proposed emissions be performed if there is reason to be concerned that new construction would cause or contribute to a Nationa l Ambient Air Quality Standard (NAAQS) or Prevention of Significant Deterioration (PSD) incre ment violation.

In addition, if the AQIA reveals that the new const ruction could cause or contribute to a NAAQS or PSD increment violation; such impacts must be reduc ed before a pre-construction permit can be issued.

To facilitate the protection of the NAAQS and PSD I ncrement, EPA Region 8 requests that those proposed activities that meet the following criteri a perform an AQIA:

1. The proposed activity has air emissions that EPA Region 8 determines have the potential to cause adverse air quality effects for which an air quality impact analysis is necessary for an accurate assessment of the environmental impact of the activities proposed.

2. Modeling of proposed emissions is usually warranted , even though the proposed activity does not meet the modeling requirements, above, if it is reasonable to believe the new activity may cause or contribute to a violation of applicable am bient air quality standards or increments in circumstances such as:

(a) A substantial portion of the new or modified emissi ons have poor dispersion characteristics (e.g., rain caps, horizontal stacks, fugitive relea ses, or building downwash ) in close proximity to ambient air at the site boundary;

(b) The new or modified emissions are located in complex terrain (e.g., terrain above stack height in close proximity to the source); or

(c) The new or modified emissions are located in areas with existing air quality concerns.

(d) If you have questions about whether modeling may be necessary based on the 4 th 

### criteria above, please contact EPA Region 8’s Modeling Lead:

Gail Tonnesen Region 8 Modeling Lead Tonnesen.gail@epa.gov 303-312- 6113Page 14 of 15 

## What Kind of Air Quality Modeling Analysis Is Neede d?

1. EPA Region 8 considers a stepped or phased approach to modeling to be appropriate, as follows:

Step 1: Qualitative Air Quality Assessment Step 2: Screening Modeling Analysis Step 3: Preliminary Modeling Analysis (refined mod eling) Step 4: Full Impact Modeling Analysis (refined mod eling) Step 5: PSD Increment and NAAQS Analysis Step 6: Additional Impact Analysis

2. Step 1: Qualitative Air Quality Assessment

Narrative description of the current air quality co nditions and the expected impact the permitted source would have on that air quality. Some sugges ted factors to consider in the qualitative discussion could include meteorology, terrain, dist ance to ambient air, expected emissions, etc. If a convincing case cannot be made qualitatively t hat no impacts to air quality would be expected, a screening analysis should next be perfo rmed.

3. Step 2: Screening Analysis

For proposed new or modified sources that meet the modeling requirement criteria identified above, protection of air quality from proposed emis sions may be shown by using a simple screening technique (e.g., SCREEN3 or AERSCREEN). Screening models are available for download at the EPA SCRAM website: http://www.epa.gov/ttn/scram/dispersion_screening.h tm . A pre-approved modeling protocol is not necessary prior to conducting a Screening Analy sis.

4. If the proposed new or modified emission increases do not increase ambient concentrations of a pollutant by more than the significant impact level s, as compared to the SILs identified below, 

### no further modeling is necessary.

**Significant Impact Levels Pollutant Averaging Period Class II Area SIL**  **(ug/m 3**  

### ) **Class I Area SIL (ug/m**  **3** 

### )

SO 2 1 hr 3 ppb or 7.8 ug/m 3 (interim) ---- 3 hr 25 1.0 24 hr 5 0.2 Annual 1 0.08


### PM 2.5 24 hr 0.07 1.2 Annual 0.06 0.3


### PM 10 24 hr 5 0.2 Annual 1 0.08


### NO 2 1 hr 4 ppb or 7.5 ug/m 3 (interim) ---- Annual 1 0.08


### CO 1 hr 2,000 ppb 8 hr 500 ppb

**Note:** The Class I area SILs are provided as guidance and have not been formalized by EPA.Page 15 of 15 

### 5. Sources that cannot demonstrate protection of air q uality using 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 refined modeling analysis (Step 3 through Step 6) t o obtain an approved protocol.


## What Should I Include In My Application If Modeling Is Necessary?

1. Approved Modeling Protocol

In order to expedite the permitting process, it is recommended that you include a protocol that has already been approved. An application will not be deemed complete until the protocol has been approved.

2. Modeling Results

In all cases, the modeling results should include t he name of the model used, all input parameters, and the resulting output. Electronic co pies of the modeling input/output files should be provided to EPA Region 8.



##  **ESA**

The Endangered Species Act requires us, in consulta tion with the U.S. Fish and Wildlife Service and/or the NOAA Fisheries Service, to ensure that a ctions we authorize are not likely to jeopardize th e continued existence of any listed species or result in the destruction or adverse modification of designated critical habitat of such species.

To expedite the approval of your proposed construct ion, we encourage you to identify any listed species that you may be readily aware of that could be affected by your proposal. The following website has been provided to assist you:

http://www.fws.gov/endangered/

Simply enter the State and County in which you prop ose to construct to obtain a general listing.



##  **NHPA**

The National Historic Preservation Act requires us, in consultation with State and/or Tribal Historic Preservation Officers to ensure that actions we aut horize are not likely to affect cultural resources.

To expedite the approval of your proposed construct ion, we encourage you to identify any cultural resources that you may be readily aware of that cou ld be affected by your proposal. The following website has been provided to assist you:

http://nrhp.focus.nps.gov/natreghome.do?searchtype= natreghome

Simply enter the State and County in which you prop ose to construct to obtain a general listing.

### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY **Region 8 Air Program FEDERAL MINOR NEW SOURCE REVIEW PROGRAM IN INDIAN C**  **OUNTRY**


## Checklist - Synthetic Minor Limit Request (Form SYNMIN) **Use of this information request form is voluntary a nd not yet approved**  **by the Office of Management and Budget.** The following is a check list of the type of informatio n that Region 8 will use to process information on your proposed project. While submittal of this form is not required, it does off er details on the information we will use to comple te your requested approval and providing the information requested may help expedi te the process. Use of application forms for this p rogram is currently under Office of Management and Budget review and these in formation request forms will be replaced/updated af ter that review is completed.

**Please submit information to following two entities :** 

Federal Minor NSR Permit Coordinator U.S. EPA, Region 8 1595 Wynkoop Avenue, 8P-AR Denver, CO 80202-1129 The Tribal Environmental Contact for the specific r eservation:

If you need assistance in identifying the appropria te Tribal Environmental Contact and address, please contact t he EPA Region 8 Tribal Air Coordinator:

Alexis North, EPA Region 8 Tribal Air Coordinator 303-312-7005 north.alexis@epa.gov



### A. GENERAL INFORMATION **Company Name** XTO Energy, Inc. **Facility Name** FBIR Iron Woman/Yellow Wolf Pad **Company Contact or Owner Name** John McMichael **Title** Environmental Engineer **Mailing Address** 810 Houston St. Ft Worth, TX 76102 **Email Address** John_McMichael@xtoenergy.com **Telephone Number** (817) 885-3782 **Facsimile Number** (817) 885-2683



### B. **ATTACHMENTS For each criteria air pollutant, hazardous air poll**  **utant and for all emission units and air pollutant**

  ** generating activities to be covered by a limitation** **, include the following:**

 **Item 1 -** The proposed limitation and a description of its ef fect on current actual, allowable and the potential to emit.  **Item 2 -** The proposed testing, monitoring, recordkeeping, an d reporting requirements to be used to demonstrate and assure compliance with the proposed limitation.  **Item 3 -** A description of estimated efficiency of air pollut ion control equipment under present or anticipated operating conditions, including documentation of th e manufacturer specifications and guarantees.  **Item 4 -** Estimates of the Post-Change Allowable Emissions th at would result from compliance with the proposed limitation, including all calculations for the esti mates.  **Item 5 –** Estimates of the potential emissions of Greenhouse Gas (GHG) pollutants before and after proposed emission controls.Page 2 of 4 

## Instructions

**Use this form to provide general and summary inform ation about the synthetic minor NSR**  **source (facility or plant) on Tribal lands and to i ndicate the emissions limitations requested.**  **Submit this form once, in addition to FORM NEW, for each synthetic minor NSR source on**  **Tribal lands.**

**1. Who Can Request Federally-Enforceable Limitation s Under the Tribal NSR Authority?** 

The Tribal NSR Rule applies only to sources located within the exterior boundaries of an Indian reservation in the United States of America or othe r lands as specified in 40 CFR part 49, collectivel y referred to as “Indian country”. So, to use the aut hority in the Tribal NSR Rule to create federallyenforceable limitations, a facility must be located within Indian country. Land ownership status (for example, whether the land is owned by a Tribal memb er or whether the land is owned in fee or in trust) does not affect how the rule applies.

**2. Who Might Want to Request Federally-Enforceable Limitations?** 

The primary reason for requesting federally-enforce able limitations is to avoid an otherwise applicabl e federal Clean Air Act program, rule or requirement. Many federal Clean Air Act programs use a source’s “potential to emit” (PTE) air pollution to determine which rules or requirements apply. A facility’s PTE is based on the maximum annual opera tional (production, throughput, etc) rate of the facility taking into consideration the capacity and configuration of the equipment and operations. Emission or operational limits can also be taken in to consideration as maximums if they are federally enforceable. So, using a synthetic minor NSR permit to establish federally enforceable limitations can lower a facility’s PTE and possibly allow the facil ity to avoid certain federal Clean Air Act requirements.

Three examples of federal Clean Air Act programs th at use PTE to determine whether they apply are (1) the Prevention of Significant Deterioration (PS D) construction permitting program, (2) the Title V operating permit program, and (3) the Maximum Achie vable Control Technology (MACT) program. For example, existing sources that are considered “ major” for Title V (meaning they have the potential to emit air pollution at levels defined in that rul e as “major”) must apply for a Title V operating pe rmit. If a source accepts a federally-enforceable limitat ion through a synthetic minor NSR permit that reduces their PTE to below the “major” threshold, a nd the source does not meet any of the other requirements that would trigger applicability to th e part 71 program, then the source no longer needs a Title V operating permit. When planning for the con struction of a new source or expansion of an existing source, a source can also accept limitatio ns on PTE (using a synthetic minor NSR permit) that allow the source to avoid PSD. Limitations on PTE c an similarly help a source to avoid new MACT standards that would otherwise apply to the source.

**3. Section B. ATTACHMENTS**

This section lists the information that must be att ached to the application form for each requested limitation. The requested limitation(s) must be des cribed for each affected emissions unit (or polluta ntgenerating activity) and pollutant and must be acco mpanied by the supporting information listed on the form and described below. Note that applicability o f many federal Clean Air Act requirements (such as Title V, PSD and MACT) is often based on facility-w ide emission levels of specific pollutants. In thatPage 3 of 4 

### case, all emissions units at a facility and all pol lutants regulated by that given rule or regulation must be addressed by this section of the application for m.

**Item 1 –** The requested limitation and its effect on actual e missions or potential to emit must be presented in enough detail to document how the limi tation will limit the source’s actual or potential emissions as a legal and practical matter and, if a pplicable, will allow the source to avoid an otherw ise applicable requirement. The information presented m ust clearly explain how the limitation affects each emission unit and each air pollutant from that emis sion unit. Use the information provided in response to Item 4 below to explain how the limitation affec ts emissions before and after the limitation is in effect.

**Item 2 –** For each requested limitation, the application must include proposed testing, monitoring, recordkeeping and reporting that will be used to de monstrate and assure compliance with the limitation. Testing approaches should incorporate a nd reference appropriate EPA reference methods where applicable. Monitoring should describe the em ission, control or process parameters that will be relied on and should address frequency, methods, an d quality assurance.

**Item 3 –** The application must include a description and esti mated efficiency of air pollution control equipment under present or anticipated operating co nditions. For control equipment that is not proposed to be modified to meet the requested limit , simply note that fact; however, for equipment tha t is proposed to be modified (e.g. improved efficienc y) or newly installed to meet the proposed limit, address both current and future descriptions and ef ficiencies. Include manufacturer specifications an d guarantees for each control device.

**Items 4 –** Any emission estimates submitted to the Regional Ad ministrator must be verifiable using currently accepted engineering criteria. The following procedures are generally acceptable for estimating emissions from air pollut ion sources:

(i) Source-specific emission tests; (ii) Mass balance calculations; (iii) Published, verifiable emission factors that a re applicable to the source. (i.e., manufacturer specifications). 

### (iv) Other engineering calculations; or (v) Other procedures to estimate emissions specific ally approved by the Regional Administrator.

Post-Change Allowable Emissions: A source’s allowa ble emissions for a pollutant is expressed in tpy and generally is calculated by multiplying the allo wed hourly emissions rate in pounds per hour (lbs/hr) times allowed hours (which is the number o f hours in a year) and dividing by 2,000 (which is the number of pounds in a ton).

**Item 5** - New construction projects that have the potenti al to emit GHG emissions of at least 100,000 tpy CO 2 

### e and 100 or 250 tpy on a mass basis, modifications at existing PSD facilities that increase GHG emissions by at least 75,000 tpy CO 2 

### e and minor sources that increase GHG emissions by at least 100,000 tpy CO 2 

### e and 100 or 250 tpy on a mass basis are subject to PSD permitting requirements, even if they do not significantly increase emissions of any other pollutant. As such, any requested limits to avoid PSD must take into account greenhouse gases.

Therefore, please include in your permit applicatio n estimates of the potential emissions of the following pollutants before and after proposed emis sion controls. More information about GHG permitting and how to calculate CO 2 

### equivalents (CO 2 

### e), the mass emissions of each individual GHGPage 4 of 4 

### adjusted for its Global Warming Potential (GWP) can be found at: http://epa.gov/nsr/ghgdocs/ghgpermittingguidance.pd f

1. Carbon dioxide (CO 2 

### ) 2. Methane (CH 4 

### ) and its CO 2 

### e 3. Nitrous oxide (N 2 

### O) and its CO 2 

### e 4. Hydrofluorocarbons (HFCs) and its CO 2 

### e 5. Perfluorocarbons (PFCs) and its CO 2 

### e 6. Sulfur hexafluoride (SF 6 

### ) and its CO 2 

### eXTO Energy, Inc. NSR Synthetic Minor Permit Application XTO211339 

## FBIR IRON WOMAN & YELLOW WOLF PAD **ATTACHMENTS:**

Attachment A: Application Report

Attachment B: Emission Inventory Spreadsheets

Attachment C: Representative Gas Analysis

Attachment D: Engine Manufacturer’s Specs

Attachment E: NSCR Control Manufacturer’s Specs

Attachment F: Enclosed Combustor Manufacturer’s Specs

Attachment G: Process Flow Diagram of Facility

Attachment H: Production Decline Curve Calculations (Confidential)

A ttachment I: Diesel Tank EPA TANKS 4.09d Emissions SummaryXTO Energy, Inc. NSR Synthetic Minor Permit Application XTO211339 

## ATTACHMENT A: APPLICATION REPORT

# APPLICATION FOR AN NSR **SYNTHETIC MINOR AIR QUALITY PERMIT**  **FBIR IRON WOMAN AND YELLOW WOLF PAD OIL & GAS**  **PRODUCTION FACILITY**

Prepared for:


## XTO Energy, Inc. **810 Houston Street Fort Worth, TX 76102** 

Prepared by:


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

## Avenue **Helena, MT 59601 (406) 442-5768**  **www.bison-eng.com**



## September 29, 2011FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. ii NSR Synthetic Minor Permit Application Project #: XTO211339 

## TABLE OF CONTENTS

1.0 INTRODUCTION ..................................

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

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

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

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

2.0 NARRATIVE DESCRIPTION..........................

................................................... ... 3

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

................................................... 5 3.1 Production Storage Tank VOC Emissions ........ ......................................... 8 3.2 Produced Casing Wellhead Gas Emissions ....... ........................................ 9 3.3 Reciprocating Internal Combustion or Compressi on Ignition Engines ....... 9 3.4 Natural Gas External Combustion Unit Emissions ..................................... 9 3.5 Truck Loading Emissions ......................

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

4.0 EMISSIONS AND OPERATIONAL LIMITS REQUESTS ..... .............................. 10 4.1 Production Storage Tank Emissions ............ ............................................ 10 4.2 Produced Casing Wellhead Gas ................. ............................................. 10 4.3 Reciprocating Internal Combustion or Compressi on Ignition Engines ..... 10

5.0 ALLOWABLE EMISSIONS ...........................

................................................... ... 12 5.1 Storage Tank Emissions .......................

................................................... 12 5.2 Produced Casing Head Gas Emissions ........... ........................................ 12 5.3 RICE Engine Emissions ........................

................................................... 12 5.4 Natural Gas External Combustion Unit Emissions ................................... 12 5.5 Truck Loading Emissions ......................

................................................... 12 5.6 Fugitive Emissions: Dust and Equipment Leaks ..................................... 12 5.7 Diesel Storage Tank Emissions ................ ............................................... 13

6.0 PROPOSED MONITORING AND RECORDKEEPING ......... ............................. 14 6.1 Production Storage Tanks .....................

.................................................. 14 6.2 Production Storage Tank Emissions Control Devi ce ............................... 15 6.3 Produced Casing Head Gas Emergency Utility Fla re .............................. 17 6.4 RICE Engines .................................

................................................... ...... 18 6.5 Natural Gas-Fired External Combustion Units .. ....................................... 18 6.6 Truck Loading ................................

................................................... ....... 19 6.7 Fugitive Equipment Leaks .....................

................................................... 19 6.8 General Recordkeeping Requirements ........... ......................................... 21

7.0 QUALITATIVE AIR QUALITY ASSESSMENT ............ ........................................ 22

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

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

9.0 NATIONAL HISTORIC PRESERVATION ACT ............ ...................................... 24FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. iii NSR Synthetic Minor Permit Application Project #: XTO211339 

## FIGURES

Figure 1: Example of Maximum PTE from a Six Well Pa d ........................................ 6 Figure 2: Example of Actual Production from a Six Well Pad ................................... 7



## ATTACHMENTS

Attachment A: Application Report Attachment B: Emission Inventory Spreadsheets Attachment C: Representative Gas Analysis Attachment D: Engine Manufacturer’s Specs Attachment E: NSCR Control Manufacturer’s Specs Attachment F: Enclosed Combustor Manufacturer’s Spe cs Attachment G: Process Flow Diagram of Facility Attachment H: Production Decline Curve Calculations (CONFIDENTIAL) Attachment I: Diesel Tank EPA TANKS 4.09d Emission s SummaryFBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 1 NSR Synthetic Minor Permit Application Project #: XTO211339 

## 1.0 **INTRODUCTION**

**1.1. Summary** 

XTO Energy, Inc. (XTO) is submitting this applicati on for a Prevention of Significant Deterioration (PSD) synthetic minor permit to the E nvironmental Protection Agency (Agency) in accordance with the requirements of the Consent Agreement dated August 29, 2011, regarding compliance with the Federal Min or New Source Review (NSR) Rule (40 CFR 49) adopted pursuant to the Federal Clean A ir Act. XTO executed the Consent Agreement to address the unique situation w here a synthetic minor source permit could not be obtained prior to commencing co nstruction because the new Tribal Minor NSR Rule August 30, 2011, implementation date did not feasibly allow time for preparation, review and processing of applications and permits.

Under the Consent Agreement, XTO is required to sub mit, by October 1, 2011, synthetic minor preconstruction permit applications for all oil and gas production facilities within the Fort Berthold Indian Reservat ion (FBIR) in North Dakota. These applications are for facilities that are anticipate d to commence construction between August 31, 2011, and December 31, 2011 (Table A-2 o f the Consent Agreement).

XTO is proposing to construct and operate the FBIR Iron Woman and Yellow Wolf Oil and Gas (O&G) production facility on the FBIR. Incl uded in this application for a synthetic minor permit are allowable emissions spec ified by requested federally enforceable permit conditions that limit the emissi ons from the facility to below the PSD major source thresholds. These limits can be found in Section 4.0 of the application.



## 1.2. **Site Location**

The FBIR Iron Woman and Yellow Wolf Pad is proposed to be located in the northwest 1⁄4

of the northeast 1⁄4 Section 10 Township 148 North, Range 92 West, Dunn County, North Dakota.



## 1.3. **Site Description**

At the proposed FBIR Iron Woman and Yellow Wolf 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 a pproximately 2,000 feet (mean sea level), in Dunn County, North Dakota. The surroundi ng area is mainly used for agriculture and livestock grazing. The proposed pad ’s associated well names are:

1. FBIR Iron Woman 21X-10-1 2. FBIR Iron Woman 21X-10-2 3. FBIR Iron Woman 21X-10-3 4. FBIR Yellow Wolf 11X-10-1 5. FBIR Yellow Wolf 11X-10-2FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 2 NSR Synthetic Minor Permit Application Project #: XTO211339 

### 6. FBIR Yellow Wolf 11X-10-3

The names of the wells may be subject to change due to landowner requirements, drilling location changes, timing of well leases, e tc. The Agency will be notified if the names change.FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 3 NSR Synthetic Minor Permit Application Project #: XTO211339 

## 2.0 NARRATIVE DESCRIPTION

This section of the application provides a detailed description of the operations at the FBIR Iron Woman and Yellow Wolf Pad. For purposes o f 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 c an be found in Attachment B, Emission Inventory.

One must note that the production rates used in thi s application are grossly overestimated when compared to the predicted produc tion actual 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 could be up to several years’ difference in when the initial production from some of the wells begin. It is not physically possible for all of the wells to be simultaneously drilled and begin initia l 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., t he wells will likely begin production at different times.

The entire pad facility will consist of the followi ng primary production equipment and capabilities.

6 - Heater Treater/Separators 6 - Line-Heaters (0.5 MMBtu/hr eac h) 24 - Oil Production Tanks 1 - Electric Recycling Pump 12 - Produced Water Tanks 6 - Electric Lifting Units 6 - Oil and Gas Producing Wells 1 - Truck Loading Rack 1 - Manufactured Produced Gas Flare 6 - LACT Units 3 - Manufactured Enclosed Tank Vapor Combustors 3 - Diesel Engines


### The oil/gas/water emulsion being produced from the wells is transported up each wellbore using an electric lifting unit, when requi red. The emulsion from the wells producing to this site is transported in a closed s ystem to individual two-phased separators and then to the three-phase separators ( heater treaters). The initial twophase separator reduces the pressure of the oil/gas /water emulsion to allow the gas to separate from the oil and water. The heater treate rs then reduce the pressure closer to ambient pressure and heat the leftover emulsion usi ng a flame-arrested line-heater. The combination of higher temperatures and low pressure s allow for additional separation of the gas/oil/water phases from each other because of differences in densities. The lineheater is fueled by onsite produced casing head gas that is routed to the heater’s combustion chamber. Propane may also be used as an alternative fuel if necessary. Following the heater treater the oil and water are routed to their separate storage tanks. The vapors from the tanks may be recovered using a vapor recovery unit (VRU) and sent to the gas sales pipeline if the capacity of t he sales line is large enough to take the vapors. However, there are three enclosed combustor s to combust the tank vapors as backup to the VRU. If it is not feasible for a VRU to be installed and operated, the combustors serve as the primary tank vapor control.FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 4 NSR Synthetic Minor Permit Application Project #: XTO211339 

### The produced casing head gas is transferred from th e heater treaters and two-phase separators to the sales gas pipeline. An onsite ut ility flare serves as an emergency backup. The oil and water production tank’s working , standing, breathing, and flashing vapors are routed to an enclosed combustion device. The stored oil is typically transported for sale via the Lease Automated Custod y Transfer (LACT) unit, with the truck loadout serving as an emergency backup if the re was a malfunction with the oil pipeline. Produced water is stored in the onsite w ater storage tank until it is transported offsite using the water pipeline.

At the facility, there is a small electric pump loc ated near the production storage tanks. This pump is commonly known as a “transfer” or “rec ycle.” The pump is used to periodically recycle the liquids (oil/water) in the bottom of the production tanks back into the heater treater for further separation. The faci lity is completely electrified when possible; however, the electricity lines have not y et been installed at the facility. Onsite diesel genset engines will provide electricity unti l transmission lines are installed.

A process flow diagram and plot plan of the site is shown in Attachment H.FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 5 NSR Synthetic Minor Permit Application Project #: XTO211339 

## 3.0 POTENTIAL TO EMIT ESTIMATE

In estimating the average production for the first twelve months, a decline curve was developed. The decline curve takes into account the fact that the initial production of the well will greatly decline over the initial twelve m onths of production. Assuming that each well’s production would be equivalent to the initia l 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 ex isting well data from wells previously drilled and producing in the same region. The confi dential decline curve estimations are included in Attachment H of the application.

As noted in Section 2.0 above, determination of pot ential emissions from the proposed FBIR Iron Woman and Yellow Wolf Pad has been approa ched in a very conservative fashion. The combined production rate for the pad assumes all of the wells start production simultaneously (represented in example F igure 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 i s that the wells will be drilled over time, often months or even years apart. Further, a fter each well is drilled and brought into production, the initial production rate genera lly 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 applicab ility purposes. Furthermore, the allowable emissions estimates presented in Section 4 are also very conservative compared to the actual emissions that could ever be emitted at the facility during any given twelve-month rolling average (represented in example Figure 2).FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 6 NSR Synthetic Minor Permit Application Project #: XTO211339 

## Figure 1: Example of Maximum PTE from a Six Well Pa **d**FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 7 NSR Synthetic Minor Permit Application Project #: XTO211339 

## Figure 2: Example of Actual Production from a Six **Well Pad**FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 8 NSR Synthetic Minor Permit Application Project #: XTO211339 

### Potential emissions from this facility originate pr imarily from the heater treater’s lineheaters emissions, the production storage tank unco ntrolled emissions, truck loading emissions, diesel genset emissions, and fugitive em issions (e.g., truck loading, equipment leaks and road dust). The maximum design capacity of the engines and natural gas-fired external combustion units, in con junction with maximum annual anticipated oil and gas production rates of this fa cility, were used in determining the facility’s potential to emit (PTE). The oil, gas, a nd water production rates were estimated by using data from recently drilled wells in the sa me region and extrapolating the rates for this proposed pad.

The potential emissions are stated in the Applicati on for New Construction (Form NEW), Table E(i) – Proposed New Facility. The emissions f rom 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 (Recyc le Pump Engine and Diesel Gensets) 4. Natural Gas External Combustion Units (Heater Tr eater Line-Heaters); 5. Truck Loading 6. Miscellaneous Fugitive Emissions (Fugitives);


## 3.1 Production Storage Tank VOC Emissions

To estimate the uncontrolled PTE of the production tank’s vapors (working, breathing, standing, and flashing), the default Bakken Pool em ission factors were used from the North Dakota Department of Health’s (NDDoH) “Bakken Pool Oil and Gas Production Facilities Air Pollution Control Permitting & Compl iance Guidance ( http://www.ndhealth.gov/AQ/OilAndGasWells_files/New %20Guidance%20O&G%20Fil es/20110502Oil%20%20Gas%20Permitting%20Guidance.pdf ). As stated on page 6 of the guidance document:

“Use of the Bakken default values to calculate VOC emissions is expected to result in a conservatively high estimate of VOC emissions... .......In the vast majority of cases, the use of site-specific data instead of the Bakken default values is expected to result in lower calculated VOC emission s.”

XTO is aware of the likelihood of overestimating th e emissions associated with the facility due to using the Bakken Pool emission fact ors. However; due to the short timeframe to submit the synthetic minor permit appl ication for the facility, XTO feels this approach will conservatively overestimate the facil ity emissions until site-specific or representative data can be sampled and analyzed to estimate emissions. All applicable uncontrolled and controlled emissions from the stor age tanks calculations are included in Attachment B.FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 9 NSR Synthetic Minor Permit Application Project #: XTO211339 

## 3.2 Produced Casing Wellhead Gas Emissions

The casing head gas at this facility is sent to the gas sales pipeline; however, due to pipeline capacity issues, XTO is conservatively est imating the PTE assuming ALL of the produced gas is being sent to their onsite high cap acity utility flare. Because the facility is connected to the gas sales pipeline, XTO is not required to estimate the PTE assuming the produced head gas emissions are being vented to the atmosphere. To calculate the flared combustions emissions, AP-42 f actors for a representative field gas analysis were used. The utility flare will meet the requirements of 40 CFR 60.18; therefore, to estimate the potential to emit, XTO i s allowed to assume 98% destruction efficiency. Again, this estimate is still very cons ervative because XTO will be selling much of their produced gas, even though all of it i s assumed to be routed to the flare.


## 3.3 Reciprocating Internal Combustion or Compressio **n Ignition Engines**

Diesel engines connected to generators provide the facility with electricity. The potential emissions from the engines are estimated by assumin g the engine is operating 8,760 hours per year and applying the federally required 40 CFR 63 Subpart JJJJ or 40 CFR 60 Subparts IIII and ZZZZ emission limits.



## 3.4 Natural Gas External Combustion Unit Emissions

The natural gas external combustion units at the fa cility are the heater treater lineheaters. Each heater is rated to a maximum capacity of 500,000 Btu/hr. The emissions are based on AP-42 factors and assume the heater is running 8,760 hours per year.


## 3.5 Truck Loading Emissions

The facility is hooked to the oil pipeline via the LACT unit; therefore, no emissions are associated with truck loading. The only time truck loading would occur is under emergency or malfunction situations.


## 3.6 Fugitive Emissions: Dust and Equipment Leaks

Fugitive emissions from equipment leaks and dust ar e not required to be estimated for purposes of potential to emit within the NSR permit ting program. However, the fugitive emissions will be estimated after a final permit is issued and production begins in order to track the twelve-month rolling average actual em issions. The fugitive leak emissions primarily consist of leaks from connectors, open-en ded lines, valves, pumps, etc. These emissions will be estimated using EPA’s average emi ssions factors for total hydrocarbon emissions from O&G production operation s. The fugitive dust emissions will be estimated using AP-42 factors to capture th e emissions associated with vehicle traffic at the location.FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 10 NSR Synthetic Minor Permit Application Project #: XTO211339 

## 4.0 EMISSIONS AND OPERATIONAL LIMITS REQUESTS

XTO is requesting emissions and operational limits at the FBIR Iron Woman and Yellow Wolf Pad in order to obtain a synthetic minor statu s with regard to the NSR permitting programs. The federally enforceable permit conditio ns will allow XTO to operate the facility while emitting less than the PSD major sou rce thresholds of 250 tons per year of a regulated criteria pollutant, 10 tons per year of an individual HAP, and 25 tons per year of all emitted HAPs.


## 4.1 Production Storage Tank Emissions

The majority of emissions associated with the facil ity occur from the working, breathing, standing, and flashing vapors from the production s torage tanks. Therefore, XTO will limit the storage tank VOC and HAP emissions by ins talling an enclosed smokeless combustion device that meets the requirements of 40 CFR 60.18. The control device XTO is installing at this facility has a guaranteed 99% control efficiency; therefore, XTO is allowed to apply 99%, rather than 98%, to the un controlled PTE. On this basis, the requested emission limit from the storage tanks is: 177.40 tons per year of VOCs and 4.92 tons per year of HAPs.


## 4.2 Produced Casing Wellhead Gas

Although XTO is connected to the gas sales pipeline , XTO is assuming that all emissions associated with the produced casing wellh ead gas are being flared to the utility flare. Only under emergency or malfunction situations with the pipeline would all of the produced gas be sent to the utility flare. Furt hermore, as previously stated, the application assumes all six of the wells are put in to production simultaneously, which is not realistic. Due to these two factors, the actual gas production at the facility would most likely not reach the estimated conservative am ount routed to the utility flare. XTO would like to note that, although CO emissions asso ciated with the combustion of the overestimated flared gas are estimated to be ~173 t ons per year, this level is unlikely to be reached. As more capacity in the sales pipeline occurs, more produced gas will be sold, ultimately achieving 100% sales, unless there is a pipeline malfunction. Therefore, no emission limit is being requested from the produ ced casing wellhead gas emissions.


## 4.3 Reciprocating Internal Combustion or Compressio **n Ignition Engines**

XTO will be required to limit the emissions from an y reciprocating internal combustion or compression ignition engine being operated at the f acility due to the federally enforceable requirements of 40 CFR 63 Subpart ZZZZ or 40 CFR 60 Subparts IIII and JJJJ. XTO will be installing one genset per two wel ls at this facility for a total of three gensets. The engines are certified to meet the Tier 3 emission standards; however, XTO is also installing nonselective catalytic reduc tion (NSCR) systems on the engines that will reduce the CO emissions by approximately 70%. The NSCRs reduce the COFBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 11 NSR Synthetic Minor Permit Application Project #: XTO211339 

### emissions from the engines to 15.36 tons per year o f CO. This reduction reduces the limits of the total allowable emissions for the fac ility to ~213 tons per year. In order to take credit for the reduction in emissions associat ed with the catalyst, XTO is requesting a permit condition requiring the use of the catalys t. In addition to the requirement for the catalyst, XTO will follow the manufacturer’s re commended maintenance schedule and follow the recordkeeping and recording requirem ents proposed in Section 6.4 of this report.FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 12 NSR Synthetic Minor Permit Application Project #: XTO211339 

## 5.0 ALLOWABLE EMISSIONS

The allowable emissions are the new estimated contr olled potential to emit based on the federally enforceable controls and limits reque sted 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 Tank Emissions

The storage tank controlled emissions are estimated by applying 99% control efficiency to the uncontrolled VOC, HAP, and CH 4 

### emissions. Although the VOC, HAP, and CH 4 

### emissions are reduced by the smokeless combustion d evice, CO, NO x 

### , PM, PM 10 

### , PM 2.5 

### and N 2 

### O 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 repr esentative gas analysis.


## 5.2 Produced Casing Head Gas Emissions

No limits have been requested for the casing wellhe ad gas utility flare emissions at the facility; therefore, the emissions estimate is equa l to the uncontrolled potential to emit.


## 5.3 RICE Engine Emissions

No limits have been requested for the RICE at the f acility. XTO is required to meet the federally enforceable emission standards depending on the size (hp) and date of manufacture; therefore, the emissions estimate is e qual to the uncontrolled potential to emit unless otherwise specified by rule or regulati on.



## 5.4 Natural Gas External Combustion Unit Emissions

No limits have been requested for the natural gas e xternal combustion units at the facility; therefore, the emissions estimate is equa l to the uncontrolled potential to emit.


## 5.5 Truck Loading Emissions

The facility is connected to the oil pipeline via t he LACT unit; therefore, no emissions are associated with truck loading. The only time tr uck loading would occur is under emergency or malfunction situations if the oil pipe line is not operational.


## 5.6 Fugitive Emissions: Dust and Equipment Leaks

Fugitive emissions from equipment leaks and dust ar e not required to be estimated for purposes of potential to emit within the NSR permit ting program. However, the fugitive emissions will be estimated after a final permit is issued in order to track the twelve-FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 13 NSR Synthetic Minor Permit Application Project #: XTO211339 

### month rolling average actual emissions. The fugitiv e leak emissions primarily consist of leaks from connectors, open-ended lines, valves, pu mps, etc. These emissions will be estimated using EPA’s average emissions factors for total hydrocarbon emissions from O&G production operations. The fugitive dust emissi ons will be estimated using AP-42 factors to capture the emissions associated with ve hicle traffic on the location.


## 5.7 Diesel Storage Tank Emissions

There will be three onsite storage tanks at this fa cility to store diesel fuel that will be utilized in the diesel gensets. These tanks will be either horizontal or vertical 1,000 gallon tanks. Emissions for these tanks were estim ated using EPA TANKS 4.09d and determined to be less than 0.01 tpy. Because of th e low level of emissions from this equipment, it has been determined to have insignifi cant emissions. The EPA TANKS 4.09d emissions summary output is in Attachment I.FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 14 NSR Synthetic Minor Permit Application Project #: XTO211339 

## 6.0 PROPOSED MONITORING AND RECORDKEEPING

According to the Application for Synthetic Minor Li mit Request (Form SYNMIN), Page 1 (B), ATTACHMENTS, Item, 2, XTO is proposing testing , monitoring, recordkeeping, and reporting requirements that will be used to demonst rate and assure compliance with the proposed allowable emissions.


## 6.1 Production Storage Tanks

The production storage tanks will have their flashi ng 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 s ale or other beneficial purposes. In the alternative an emissions control device that achiev es a minimum of 99% destruction efficiency may be used. XTO will follow the tank ma nufacturer’s recommended maintenance schedule and procedures to ensure optim um performance. Furthermore, XTO 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 rele ase 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 sal e or other beneficial purpose, or to an emissions control device; and c. Quarterly observations of the peak pressure and vacuum values in the vapor recovery and control systems will be conducted to e nsure 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:

XTO 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/b reathing losses; c. Direct measurement of flashing emissions by samp ling and lab analysis; d. Process simulator such as PROMAX, HYSIM, HSYS us ing site-specific sampling and lab analysis to calculate flashing emissions in conjunction with EPA TANKS 4.0.9d to calculate standing/working/breathing loss es; 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.FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 15 NSR Synthetic Minor Permit Application Project #: XTO211339 

### Recordkeeping Requirements:

Total VOC, total HAP, and any single HAP emissions from production storage tanks will be calculated and recorded at the end of each month , beginning with the first full calendar month after operations commenced. Prior t o twelve full months of operation, XTO will, at the end of each month, add the emissio ns for that month to the calculated emissions for all previous months since operations commenced, where applicable, and record the total. Thereafter, XTO will, at the end of each month, add the emissions for that month to the calculated emissions for the prec eding eleven months and record a new twelve-month total.

XTO will keep records of all input parameters and c alculations, including the input and output reports for the models, used to determine th e monthly emissions.


## 6.2 Production Storage Tank Emissions Control Devic **e**
The limits requested on the emissions from the stor age tanks are directly dependent on the production throughput in the tanks. All emissi ons at the facility will be controlled by one or more enclosed combustors and/or utility flar es that are designed and operated to reduce the mass content of VOC (or VOC and HAP) emi ssions in the vapors vented to the device by at least 98%.

For each enclosed combustion device and utility fla re, XTO will follow the manufacturer’s written operating instructions, proc edures and maintenance schedule to ensure good air pollution control practices for min imizing emissions.

All vent lines, connections, fittings, valves, reli ef valves, or any other appurtenance employed to contain and collect vapors and transpor t them to the enclosed combustor, or utility flare will be maintained and operated du ring any time the facility is operating.

Each enclosed combustion device will be:

a. Designed to have sufficient capacity to achieve at least a 98% destruction efficiency for the hydrocarbon volumetric flow and BTU content routed to the device; b. Operated with a liquid knock-out system to conde nse any condensable vapors; c. Equipped with a thermocouple to detect the prese nce of a pilot flame with a minimum accuracy of ±2 percent of the temperature b eing monitored expressed in °C, or ±2.5 °C; d. Equipped with a recording device, such as a char t recorder or similar device, to document the presence of a flame; e. Equipped with an electronically controlled ignit ion system with a malfunction alarm and remote notification system if the pilot f lame fails; f. Maintained in a leak-free condition; and g. Operated in a smokeless mode.FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 16 NSR Synthetic Minor Permit Application Project #: XTO211339 

### Monitoring Requirements:

XTO has identified a manufacturer or vendor that gu arantees the enclosed combustor will meet, at minimum, the 98.0% reduction requirem ent. XTO will monitor the control device operations to confirm proper operation as fo llows:

a. Monitor the pilot flame using a thermocouple and a chart recorder that indicates the continuous ignition of the pilot flame; b. A check of the chart recorder to ensure proper o peration will be done whenever an operator is on site; at a minimum, quarterly; c. A check of the pilot flame to ensure proper oper ation will be done whenever an operator is on site; at a minimum, quarterly; d. Measure one other parameter determined during th e independent engineering analysis or provided for in a manufacturer or vendo r 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 of the site-specific design input parameters provided through the independent engineering analysis or fro m the manufacturer or vendor and used to properly size the enclosed combu stors and utility flares to assure the, at minimum, 98% reduction requirements; b. Records will be kept of all required monitoring of the control device operations; c. Records will be kept of any instances in which a ny 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 me asures adopted to avoid such bypasses or downtimes; d. Records will be kept of the exceedances of the o perating 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 t he exceedance occurred, the date, time and length of time that the parameters w ere exceeded, and the corrective actions taken or the preventative measur es adopted to operate the facility within that operating parameter; e. Records will be kept of any instances in which t he pilot flame is not present in the enclosed combustor or the utility flare, the date a nd times that the pilot was not present and the corrective actions taken or the pre ventative measures adopted to increase the operating time of the pilot flame; f. Records will be kept of any instances in which t he thermocouple (or other heat sensing monitoring device) installed to detect the presence of a flame in the enclosed combustor or utility flare is not operatio nal, the time period during which it was not operational, and the corrective measures taken;FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 17 NSR Synthetic Minor Permit Application Project #: XTO211339 

### g. Records will be kept of any time periods in whic h visible emissions from an enclosed combustor or utility flare are observed; 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 observati ons and the analyses; iv. Analytical techniques or methods used; v. Results of such analyses or measurements; and vi. Operating conditions as existing at the time of sampling or measurement. i. Monitor the pilot flame using a thermocouple and a chart recorder that indicates the continuous ignition of the pilot flame; j. A check of the chart recorder to ensure proper o peration will be done whenever an operator is on site; at a minimum, quarterly; k. A check of the pilot flame to ensure proper oper ation will be done whenever an operator is on site; at a minimum, quarterly; l. Measure one other parameter determined during th e independent engineering analysis or provided for in a manufacturer or vendo r 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.

For each enclosed combustion device and utility fla re, XTO will follow the manufacturer’s written operating instructions, proc edures and maintenance schedule to ensure good air pollution control practices for min imizing emissions.


## 6.3 Produced Casing Head Gas Emergency Utility Flar **e**
XTO is not requesting any limits from the produced casing head gas because it is being sent to the gas sales pipeline. If a malfunction fr om the pipeline occurs and the gas cannot be sold, XTO will record the volume of gas s ent to the emergency utility flare.

During an emergency or malfunction XTO will route t he 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%. XTO will follow the manufacturer’s written operatin g instructions, procedures and maintenance schedule to ensure good air pollution c ontrol practices for minimizing emissions.

All vent lines, connections, fittings, valves, reli ef valves, or any other appurtenance employed to contain and collect vapors and transpor t them to the utility flare will be maintained and operated during any time the facilit y is operating.

The emergency utility flare will be: a. Designed and operated in accordance with the req uirements of 40 CFR 60.18 and 40 CFR 63.11.FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 18 NSR Synthetic Minor Permit Application Project #: XTO211339 

### b. Designed to have sufficient capacity to achieve at least a 98% destruction efficiency for the hydrocarbon volumetric flow and BTU content routed to the device; c. Operated with a liquid knock-out system to conde nse any condensable vapors; d. Equipped with a thermocouple to detect the prese nce of a pilot flame with a minimum accuracy of ±2 percent of the temperature b eing monitored (expressed in °C), or ±2.5 °C; e. Equipped with a recording device, such as a char t recorder or similar device, to document the presence of a flame; f. Equipped with an electronically controlled ignit ion system with a malfunction alarm and remote notification system if the pilot f lame fails; g. Maintained in a leak-free condition; and h. Operated in a smokeless mode.

Monitoring Requirements:

The monitoring requirements for the emergency utili ty flare will be the same as described above for the production storage tanks co ntrol device as specified in Section 6.2.

Recordkeeping Requirements:

The recordkeeping requirements for the emergency ut ility flare will be the same as described above for the production storage tanks co ntrol device as specified in Section 6.2.


## 6.4 RICE Engines

Depending on the size (hp) and date of manufacture, XTO is required to meet the emission standards set forth in 40 CFR 63 Subpart J JJJ or 40 CFR 60 Subparts IIII and ZZZZ. XTO will properly operate and maintain the en gines per the manufacturer’s specifications to ensure compliance with the above standards. If the engines emissions are not certified to meet the required standards, X TO will have performance tests performed on the engines as required by the applica ble subparts. XTO will also operate and maintain the NSCRs to the manufacturer’s specif ication to ensure maximum performance of the control devices.



## 6.5 Natural Gas-Fired External Combustion Units

Due to the insignificant emissions associated with the 0.5 MMBtu/hr natural gas (or propane) fired line-heaters, no monitoring or recor dkeeping requirements are being proposed by XTO. Furthermore, XTO would like to poi nt out that the emissions associated with the line-heaters were estimated bas ed on 8,760 hours of operation per year when, in reality, the heaters are not used tha t often due to the high temperature of the emulsion from the wells.FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 19 NSR Synthetic Minor Permit Application Project #: XTO211339 

## 6.6 Truck Loading

LACT units are utilized to transport the oil and wa ter at this facility into their respective pipelines. However, there is a truck loading rack a t the facility in case of a malfunction. If the truck loading rack must be used in an emergency or malfunction situation, the tank trucks will be loaded using submerged fill.


## 6.7 Fugitive Equipment Leaks

XTO will minimize leaks of volatile organics from e ach piece of equipment in hydrocarbon service at this facility.

Work Practice and Operational Requirements:

a. At a minimum, XTO will detect and repair leaks a t each tank thief hatch, centrifugal compressor vent, reciprocating compress or vent, instrument, meter, diaphragm, pressure relief device, dump arm, open-e nded valve or line, vent line, flange, connection, fitting, or any other appurtena nce employed to contain and collect vapors and transport them. b. XTO will make the first attempt to repair any le aking equipment within five days after the leak is detected. c. Any leaking equipment will be repaired as soon a s practicable, but no later than 15 days after the leak is initially detected, unles s the repair is technically infeasible without a facility shutdown or inaccessi ble due to weather conditions. Such equipment will be repaired before the end of t he first facility shutdown, after the leak is initially detected. XTO will make the f irst attempt to repair any leaking equipment within five days after the leak is detect ed. XTO will minimize leaks of volatile organics from each piece of equipment in h ydrocarbon service at this facility.

Monitoring Requirements:

a. XTO will conduct leak detection monitoring on an quarterly basis. If no instrument reading of 10,000 ppm or greater is meas ured for two consecutive quarterly monitoring periods, the required monitori ng frequency will change from quarterly to semi-annual. 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 t o annual. If any single instrument reading of 10,000 ppm or greater is meas ured, the required monitoring frequency will change back to quarterly. b. XTO will use one of the following methods to con duct leak detection of the equipment: i. Method 21 a) Use the equipment leak detection methods in 40 C FR Part 60, Appendix A–7, Method 21; andFBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 20 NSR Synthetic Minor Permit Application Project #: XTO211339 

### b) If an instrument reading of 10,000 ppm or greate r is measured, a leak is detected. ii. Optical Gas Imaging Instrument a) Use an optical gas imaging instrument for equipm ent leak detection in accordance with 40 CFR Part 60, Subpart A, §60.18(i )(1) and (2) of the Alternative work practice for monitoring equipment leaks; b) Any emissions detected by the optical gas imagin g instrument are a leak unless screened with Method 21 (40 CFR Part 60, App endix 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 t he equipment in addition to any observed leaks; and d) The optical gas imaging instrument will be opera ted 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 ap proved by EPA, based on best management practices, for leak detection; b) Any emissions detected by the protocol are a lea k 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 pr actice 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 requir ed recordkeeping for equipment leaks; and III. A requirement that the log book be signed by t he inspector at the completion of each inspection.

Recordkeeping Requirements:

a. XTO will document and maintain a record of each leak detection inspection and repairs. b. All leak detection inspection records will inclu de, at a minimum, the following information: i. Date of the inspection; ii. All documentation and/or images produced in the inspection; iii. Findings of the inspection; iv. Any corrective action taken; and v. Inspector's name and signature.FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 21 NSR Synthetic Minor Permit Application Project #: XTO211339 

## 6.8 General Recordkeeping Requirements

Total VOC (or VOC, total HAP, and any single HAP) e missions, 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 comm enced. Prior to twelve full months of operation, XTO 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, XTO will, at the end of each month, add the emissions for that month to the calculated emission s for the preceding eleven months and record a new twelve-month total.

XTO, when feasible, may use a Supervisory Control a nd 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, producti on monitoring, electronic pressure indicating transmitters, pilot flame status monitor ing, valve position set-points, temperature monitoring, alarm notification, data lo gging, flowmeter monitoring, etc.FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 22 NSR Synthetic Minor Permit Application Project #: XTO211339 

## 7.0 QUALITATIVE AIR QUALITY ASSESSMENT

The climatology and air quality of the area of inte rest is dominated by continental air masses with only minor terrain features (from a syn optic 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 con trast 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 n ear the reservation for many years. The results of that ambient monitoring network indi cate ambient concentrations of all pollutants well below the National Ambient Air Qual ity Standards (40 CFR 50). Those measured values include the impact of substantial o il and gas development that has occurred in the region including development near t he proposed facility. In fact, much of the monitoring data yields background values despit e the presence of current industrial activity and general anthropogenic sources. The rep orted data shows that the values are the same or nearly the same as one would find i n a rural location devoid of any industrial activity (although industrial activity i s clearly nearby).

A typical facility’s actual emissions are modest in nature (i.e., below typical permitting thresholds) as demonstrated in Figure 2; therefore, additional ambient impact analysis is not warranted.FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 23 NSR Synthetic Minor Permit Application Project #: XTO211339 

## 8.0 ENDANGERED SPECIES ACT

The Endangered Species Act (ESA) requires EPA, in c onsultation with the U.S. Fish and Wildlife Service (USFWS) and/or the NOAA Fisher ies Service, to ensure that actions EPA authorizes are not likely to jeopardize the continued existence of any listed threatened or endangered species (TES) or result in the destruction or adverse modification of designated critical habitat of such species.
TES are considered to be those species recognized b y 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 w ill first be assessed by consulting the USFWS North Dakota Ecological Service Field Office website ( http://www.fws.gov/northdakotafieldoffice/index.htm ) and noting the potential occurrence of each TES by county. Once the potenti al presence of a species is assessed, a look at whether any critical habitat ex ists 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 an d mitigation of any impacts.FBIR Iron Woman and Yellow Wolf Pad 09/29/11 pg. 24 NSR Synthetic Minor Permit Application Project #: XTO211339 

## 9.0 NATIONAL HISTORIC PRESERVATION ACT

The National Historic Preservation Act requires EPA , in consultation with State and/or Tribal Historic Preservation Officers, to ensure th at actions authorized are not likely to affect cultural resources.

The potential for cultural resources in the vicinit y of the facility will be assessed by consulting with the North Dakota State Historic Pre servation Office (NDSHPO) and the Tribal Historic Preservation Officer(s), and conduc ting a literature review of available information from the area immediately surrounding t he facility (http://history.nd.gov/hp/siclass1.html). If the r eview finds a need for more intensive analysis of the immediate area of the facility, a C lass 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 impact s.XTO Energy, Inc. NSR Synthetic Minor Permit Application XTO211339 

## ATTACHMENT B: EMISSION INVENTORY **SPREADSHEETS**GREEN = Requires input RED = No input required. This is a calculated value. Facility Information

FBIR Iron Woman and Yellow Wolf Pad Associated Wells: Iron Woman 21X-10-1, 21X-10-2, 21X-10-3, Yellow Wolf 11-10-1, 11-10-2, 11-10-3 Name of the facility and the well number. Unknown Approximate first date of production or the date of modificatio n of the facility. 9/30/2011 Date application packet is submitted to the EPA Region 8.

Production Data Description BOPD 3354 Average daily production in barrels of oil per day (BOPD), based on the predicted first 30 days of production. Mscfd 3354 Average daily production of gas in Mscf per day, based on the predicted first 30 days of production. Decline Factor 0.545 Expected decline factor for the first year of operation. Based on data from previsously producing wells in the same field and formation. Adjusted BOPD 1827.93 This is the calculated BOPD expected to be produced using the above entered decline factor. Adjusted Produced Gas (Mscfd) 1827.93 This is the calculated mcfd of gas the well is expected to produce using the above entered decline factor.

Oil/Condensate Tank Data Description Flash Gas Method: Default Bakken EF Use the drop down menu to choose the appropriate flash gas method. Bakken EF scf/bbl 97.91 The scf/bbl from direct measurement or representative sample. If specific data is not available, use the Bakken default of 97.91. Estimated Tank Vapors (scfd) 178973 This is the estimated scfd of tank vapors based on the following: adju sted BOPD multiplied by the scf/bbl entered on Line 9. Lower Heating Value 2000 Lower heating value (Btu/scf) of tank vapors. If site specific data is no t available, use the Bakken default value of 2000. Molecular Weight 45.19 Molecular weight of the tank vapors in pounds per pound-mole (lb /lb-mole). If site specific data is not available, use the Bakken default val ue of 45.19. VOC% 79.80% VOC weight fraction of the tank vapor gas (C3+). If site specific d ata is not available, use the Bakken default value of 79.8%. HAP% 2.26% HAP weight fraction of the tank vapor gas. If site specific data is n ot available, use the Bakken default value of 2.26%. CO2% 1.02% CO2 weight fraction of the tank vapor gas. (Assumed to be equal to the field gas data.) CH4% 16.92% CH4 weight fraction of the tank vapor gas. (100%-VOC wt% -CO2 wt%)
H 2 S weight % 0.00% H 2 S weight percent of the tank vapor gas.
H 2 S mole % 0.00% H 2 S mole percent of the tank vapor gas. Utility Flare or Other 98% DRE Device Use the drop down menu to choose the appropriate emission control type. Control Destruction Efficiency 99% Control efficiency of any applicable controls. This is a fixed number based on control type. (Vendor Guarantee.) 

# XTO Energy, Inc.

Input DataGREEN = Requires input RED = No input required. This is a calculated value. 

# XTO Energy, Inc.

Input Data

Treater Gas Data Description Btu/scf 1401.5 Btu/scf of wellstream gas. (From representative field gas analysis) Molecular Weight 24.49 Average molecular weight of the wellstream gas in lb/lb-mole. (From representative field gas analysis) Specific Gravity 0.8476 If necessary to convert specific gravity to molecular weight, enter the specif ic gravity of the wellstream gas. (From representative field gas analysis) Calculated Molecular Weight 24.55 This is the calculated molecular weight based on the specific gravity entered above. Please enter this number on Line 21. VOC% 32.88% VOC weight fraction of the wellstream gas (Note: Weight%, not M ole%). (From representative field gas analysis) HAP% 0.02% HAP weight fraction of the wellstream gas. (Note: Weight%, not Mole%). (From representative field gas analysis) CO2% 1.022% CO2 weight fraction of the wellstream gas. (Note: Weight%, not Mole%). (From representative field gas analysis) CH4% 43.112% CH4 weight fraction of the wellstream gas. (Note: Weight%, not Mole%). (From representative field gas analysis)
H 2 S weight % 0.000% H 2 S weight percent of the wellstream gas. (From representative field gas analysis)
H 2 S mole % 0.000% H 2 S mole percent of the wellstream gas. (From representative field gas analysis)
Connected to sales line Use the drop down menu to choose the appropriate emission control type.

Treater Burner(s) Description Total Btu/hr 3000000 Total burner rating for the heater treater burner(s) in btu/hr. If there are multiple burners, add the total heat input togeth er. Hours of Operation 8,760 The burner(s) is/are assumed to operate 8,760 hours per year.

Truck Loading Description Oil is sold through LACT Use the drop down menu to choose the appropriate oil sales method. If oil is sold through a LACT, no input values are required in Lines 30-35. Submerged loading: dedicated normal service 0.6 Use the drop down list to choose the appropriate mode of operatio n. The saturation factor will automatically be selected based on mode of operation. Molecular Weight 45.19 Molecular weight of tank vapors in lb/lb-mole. Assumed same molecular weight as flashing emissions from representative E&P Tanks data. Vapor Pressure 2.30 True vapor pressure of liquid loaded, pounds per square inch absolut e (psia) If no site specific data is available, please refer to Table 2 on th e Truck Loading tab. Temperature 50.00 Temperature of bulk liquid loaded in Farenheit. If no site specifi c data is available, use an estimated average annual temperature. Load Rate (bbl/hr) 180 Load rate of liquid loaded in barrels per hour. Load Time (hrs) 1.00 The time it takes to loadout one load (hrs).

Pneumatic Pumps Description Number of Pneumatic Pumps 0 Number of pneumatic pumps at facility. Hours of Operation 0 Hours the pump is in operation annually. For winter months on ly, please enter 4380 hours. scf/min 0.00 Pneumatic source consumption rate as per manufacturer data (scf/min). Routed exhaust back into closed loop system Use the drop down menu to choose the appropriate emission control type. Control Efficiency 100% Control efficiency of any applicable controls (combustor, routing exhaust to fuel supply, VRU, etc).

Pneumatic Controllers Description Number of Pneumatic Controllers 0 Number of pneumatic controllers at facility. Bleed rate (scf/hr) 0.00 Average bleed rate of device (scf/hr).

Glycol Dehydrator Description VOC (TPY) 0.00 VOC emissions calculated in GRI-GLYCalc software (if no glycol dehydr ator enter 0). HAP (TPY) 0.00 HAP emissions calculated in GRI-GLYCalc software (if no glycol dehydr ator enter 0).Facility:
FBIR Iron Woman and Yellow Wolf Pad Associated Wells: Iron Woman 21X-10-1, 21X-10-2, 21X-10-3, Yellow Wolf 11-10- 1, 11-10-2, 11-10-3

VOC HAP NOx PM PM10 PM2.5 CO H 2 S SO 2 HCHO
Oil/Condensate Tanks 3107.82 37.23 N/A N/A N/A N/A N/A N/A N /A Negligible Casing Head Gas 7088.13 206.08 31.79 2.54 2.54 2.54 172.99 NA 0.00 0.03 Treater Burner 0.07 0.02 1.29 0.10 0.10 0.10 1.08 N/A 0.01 Ne gligible RICE Engine 4.49 2.01E-05 54.60 2.95 2.95 2.95 15.36 N/A 8.9 0E-05 0.00 Truck Loading N/A N/A N/A N/A N/A N/A N/A N/A N/A Negligible Pneumatic Pump N/A N/A N/A N/A N/A N/A N/A N/A N/A Negligible Pneumatic Controllers N/A N/A N/A N/A N/A N/A N/A N/A N/A Neg ligible Glycol Dehydrator N/A N/A N/A N/A N/A N/A N/A N/A N/A Negligi ble

Totals (TPY) 10200.51 243.33 87.68 5.59 5.59 5.59 189.44 0. 00 0.01 0.03

VOC HAP NOx PM PM10 PM2.5 CO H 2 S SO 2 HCHO
Oil/Condensate Tanks 31.08 0.74 4.44 0.25 0.25 0.25 24.17 N /A N/A Negligible Casing Head Gas 141.76 4.15 31.79 2.54 2.54 2.54 172.99 0.0 0 0.00 0.03 Treater Burner 0.07 0.02 1.29 0.10 0.10 0.10 1.08 N/A 0.01 Ne gligible RICE Engine 4.49 2.01E-05 54.60 2.95 2.95 2.95 15.36 N/A 8.9 0E-05 0.00 Truck Loading N/A N/A N/A N/A N/A N/A N/A N/A N/A Negligible Pneumatic Pump N/A N/A N/A N/A N/A N/A N/A N/A N/A Negligible Pneumatic Controllers N/A N/A N/A N/A N/A N/A N/A N/A N/A Neg ligible Glycol Dehydrator N/A N/A N/A N/A N/A N/A N/A N/A N/A Negligi ble

Totals (TPY) 177.40 4.92 92.13 5.84 5.84 5.84 213.61 0.00 0. 01 0.03 Allowable Potential to Emit 

# XTO Energy, Inc.

Emission Summary

Uncontrolled Potential to Emit Criteria Pollutants

Criteria Pollutants aFacility:
FBIR Iron Woman and Yellow Wolf Pad Associated Wells: Iron Woman 21X-10-1, 21X-10-2, 21X-10-3, Yellow Wolf 11-10- 1, 11-10-2, 11-10-3 

# XTO Energy, Inc.

a Emissions of lead and lead compounds, flourides, su lfuric acid mist, total reduced sulfur and reduced sulfur compounds have been determined to be neglig able

CO 2 CH 4 N 2 O CO 2 CH 4 N 2 O
Oil/Condensate Tanks N/A 658.88 N/A 3959.30 0.00 0.08 Casing Head Gas 40251.95 9293.26 0.04 40251.95 185.87 0.0 4 Treater Burner 1545.88 0.09 0.02 1545.88 0.09 0.02 RICE Engine 4.99E-02 0.41 0.08 4.99E-02 0.41 0.08 Truck Loading 0.00 0.00 N/A 0.00 0.00 N/A Pneumatic Pump N/A N/A N/A N/A N/A N/A
Pneumatic Controllers N/A N/A N/A N/A N/A N/A Glycol Dehydrator N/A N/A N/A N/A N/A N/A

Totals (TPY) 41797.88 9952.64 0.14 45757.18 186.37 0.22

GHG Mass Emissions (tpy): 51750.66 GHG Mass Emissions (tpy): 45943.76 CO2e (tpy): 250847.32 CO2e (tpy): 49738.17 Applicable to the Tailoring Rule?: No

b Hydrofluorocarbons (HFCs), Perfluorocarbons (PFCs), and Sulfur Hexafluorides (SF6) emissions are not c reated from O&G production operations. Actual Greenhouse Gases b Potential To Emit Greenhouse Gases bBOPD

scf/day

Btu/scf

lb/lb-mole

HAPs: Benzene wt Fraction (Assumed to be equal to gas sales wt fraction.) Toluene wt Fraction (Assumed to be equal to gas sales wt fraction.) E-Benzene wt Fraction (Assumed to be equal to gas sales wt fraction.) Xylene wt Fraction (Assumed to be equal to gas sales wt fraction.) n-Hexane wt Fraction (Assumed to be equal to gas sales wt fraction.) 2,2,4-Trimethylpentane wt Fraction (Assumed to be equal to gas sales wt fraction.)

Controlled emissions are calculated based on a 99% destruction efficiency of the VOC gas. 

# XTO Energy, Inc.

FBIR Iron Woman and Yellow Wolf Pad Associated Wells: Iron Woman 21X-10-1, 21X-10-2, 21 X-10-3, Yellow Wolf 11-10-1, 11-10-2, 11-10-3



## Tanks

Flare Gas Volume 178,973 Oil Production 1828

Lower Heating Value 2000

Molecular Weight 45.19

VOC wt Fraction 79.80%

0.0763%

0.0031% 0.0337%

0.7394% 0.0126%

0.0908%

CH4 wt Fraction 1.02%

16.92% CO2 wt Fraction

# XTO Energy, Inc.

FBIR Iron Woman and Yellow Wolf Pad Associated Wells: Iron Woman 21X-10-1, 21X-10-2, 21 X-10-3, Yellow Wolf 11-10-1, 11-10-2, 11-10-3



## Tanks

Uncontrolled VOCs (PTE):
DRE VOC: 7,457 scf/hr x x 45.19 lb/lb-mole x 79.80% x 0% = lb/hr

709.55 lb/hr x x = TPY

Controlled VOCs (Allowable):
DRE VOC: 7,457 scf/hr x x 45.19 lb/lb-mole x 79.80% x 99% = lb/hr

7.10 lb/hr x x x TPY

Uncontrolled HAPs (PTE): Using E&P Tanks Run: wt% DRE TPY Benzene 7,457 scf/hr x x 1/379 scf/lb-mole x 45.19 lb/lb-mol x 0.08% x 0% = 0.68 lb/hr 2.97 E-Benzene 7,457 scf/hr x x 1/379 scf/lb-mole x 45.19 lb/lb-mol x 0.00% x 0% = 0.03 lb/hr 0.12

Toluene 7,457 scf/hr x x 1/379 scf/lb-mole x 45.19 lb/lb-mol x 0.03% x 0% = 0.30 lb/hr 1.31 n-Hexane 7,457 scf/hr x x 1/379 scf/lb-mole x 45.19 lb/lb-mol x 0.74% x 0% = 6.57 lb/hr 28.80

Xylene 7,457 scf/hr x x 1/379 scf/lb-mole x 45.19 lb/lb-mol x 0.01% x 0% = 0.11 lb/hr 0.49 2,2,4-Trimethylpentane 7,457 scf/hr x x 1/379 scf/lb-mole x 45.19 lb/lb-mol x 0.09% x 0% = 0.81 lb/hr 3.54

Uncontrolled TOTAL HAPS (TPY) 37.23

Controlled HAPs (Allowable):
Benzene 7,457 scf/hr x x 1/379 scf/lb-mole x 45.19 lb/lb-mol x 0.08% x 98% = 0.01 lb/hr 0.06 E-Benzene 7,457 scf/hr x x 1/379 scf/lb-mole x 45.19 lb/lb-mol x 0.00% x 98% = 0.00 lb/hr 0.00

Toluene 7,457 scf/hr x x 1/379 scf/lb-mole x 45.19 lb/lb-mol x 0.03% x 98% = 0.01 lb/hr 0.03 n-Hexane 7,457 scf/hr x x 1/379 scf/lb-mole x 45.19 lb/lb-mol x 0.74% x 98% = 0.13 lb/hr 0.58

Xylene 7,457 scf/hr x x 1/379 scf/lb-mole x 45.19 lb/lb-mol x 0.01% x 98% = 0.00 lb/hr 0.01 2,2,4-Trimethylpentane 7,457 scf/hr x x 1/379 scf/lb-mole x 45.19 lb/lb-mol x 0.09% x 98% = 0.02 lb/hr 0.07

Controlled TOTAL HAPS (TPY) 0.74 709.55

8760 hr/yr 3107.82

7.10

31.08

= =

=

=

=

=

=

=

= =

= =

=

= 1/379 scf/lb-mole

1/379 scf/lb-mole

1 ton/2000 lb 1 ton/2000 lb

8760 hr/yr 

## CRITERIA POLLUTANT EMISSIONS a

# XTO Energy, Inc.

FBIR Iron Woman and Yellow Wolf Pad Associated Wells: Iron Woman 21X-10-1, 21X-10-2, 21 X-10-3, Yellow Wolf 11-10-1, 11-10-2, 11-10-3



## Tanks

Uncontrolled NOx:

NOx: 0 scf/hr x 2,000 Btu/scf x x 0.068 lb/MMBtu = 0.00 lb/hr

0.00 lb/hr x x 0.00 TPY

NOx Created by Combustion (Actual)

NOx: 7,457 scf/hr x 2,000 Btu/scf x x 0.068 lb/MMBtu = 1.01 lb/hr

1.01 lb/hr x x 4.44 TPY

Uncontrolled PM:

PM: 0 scf/hr x 7.6 lb/1,000,000 scf = 0.00 lb/hr

0.00 lb/hr x 8760 hr/yr x 0.00 TPY

PM Created by Combustion (Actual)

PM: 7,457 scf/hr x 7.6 lb/1,000,000 scf = 0.06 lb/hr

0.06 lb/hr x 8760 hr/yr x 0.25 TPY 1 MMBtu/1,000,000 Btu

8760 hr/yr 1 ton/2000 lb =

=

1 ton/2000 lb = 1 ton/2000 lb = 1 ton/2000 lb 1 MMBtu/1,000,000 Btu

8760 hr/yr

# XTO Energy, Inc.

FBIR Iron Woman and Yellow Wolf Pad Associated Wells: Iron Woman 21X-10-1, 21X-10-2, 21 X-10-3, Yellow Wolf 11-10-1, 11-10-2, 11-10-3



## Tanks

Uncontrolled CO:

CO: 0 scf/hr x 2,000 Btu/scf x x 0.370 lb/MMBtu = 0.00 lb/hr

0.00 lb/hr x x 0.00 TPY

CO Created by Combustion (Actual)

CO: 7,457 scf/hr x 2,000 Btu/scf x x 0.370 lb/MMBtu = 5.52 lb/hr

5.52 lb/hr x x 24.17 TPY

a NOx, SO2, and CO emission factors are from AP-42 Ta ble 13.5-1 (Emission Factors for Flare Operations).

Uncombusted CO2:

wt DRE CO2: 7,457 scf/hr x x 45.19 lb/lb-mole 1.02% x 0% = lb/hr

lb/hr x 8760 hr/yr x = TPY

CO2 Created by Combustion (Actual)

CO2: 7,457 scf/hr x 120,000.0 lb/1,000,000 scf = lb/hr

894.86 lb/hr x 8760 hr/yr x = 3919.50 TPY 

## REGULATED GREENHOUSE GAS EMISSIONS b = 1 MMBtu/1,000,000 Btu

8760 hr/yr 1 ton/2000 lb

9.09 1 MMBtu/1,000,000 Btu

8760 hr/yr 1 ton/2000 lb =

1 ton/2000 lb x 1/379 scf/lb-mole

1 ton/2000 lb 9.09

39.80

894.86

# XTO Energy, Inc.

FBIR Iron Woman and Yellow Wolf Pad Associated Wells: Iron Woman 21X-10-1, 21X-10-2, 21 X-10-3, Yellow Wolf 11-10-1, 11-10-2, 11-10-3



## Tanks

Uncontrolled CH4:

wt DRE CH4: 7,457 scf/hr x x 45.19 lb/lb-mole 16.92% x 0% = lb/hr

lb/hr x 8760 hr/yr x = TPY

Controlled CH4: (Actual)

wt% DRE CH4: 7,457 scf/hr x x 45.19 lb/lb-mole 16.92% x 99% = lb/hr

lb/hr x 8760 hr/yr x = TPY

Uncontrolled N2O:

wt% DRE CH4: 7,457 scf/hr x x 45.19 lb/lb-mole 0.00% x 0% = lb/hr

lb/hr x 8760 hr/yr x = TPY

N2O Created by Combustion:

CH4: 7,457 scf/hr x 2.3 lb/1,000,000 scf = lb/hr

0.02 lb/hr x 8760 hr/yr x = 0.08 TPY

b CO2 and N2O emission factors are from AP-42 Table 1 .4-2 (Emission Factors for Natural Gas Combustion). x 150.43

150.43 658.88 1/379 scf/lb-mole

1 ton/2000 lb

x

0.00 0.00

0.02

1 ton/2000 lb

x 0.00 1.50

1.50 6.59 1/379 scf/lb-mole

1/379 scf/lb-mole

1 ton/2000 lb 1 ton/2000 lbscfd

Btu/scf

lb/lb-mole

HAP wt fractions Benzene wt fraction E-Benzene wt fraction

Toluene wt fraction n-Hexane wt fraction

Xylene wt fraction 2,2,4-Trimethylpentane wt fraction

CO2 wt fraction

CH4 wt fraction

DRE 0.08% 0.00% 0.03% 0.74% 0.01%

0.09%

1.02%

43.11%

98% 

### FBIR Iron Woman and Yellow Wolf Pad Associated Wells: Iron Woman 21X-10-1, 21X-10-2, 21 X-10-3, Yellow Wolf 11-10-1, 11-10-2, 11-10-3



## Treater Flare

Flare Gas Volume 1,827,930

Lower Heating Value 1401.5

Avg. Molecular Weight 24.49

VOC wt fraction 32.88% 

# XTO Energy, Inc.

Flare Combustion Efficiency:

### FBIR Iron Woman and Yellow Wolf Pad Associated Wells: Iron Woman 21X-10-1, 21X-10-2, 21 X-10-3, Yellow Wolf 11-10-1, 11-10-2, 11-10-3



## Treater Flare 

# XTO Energy, Inc.

Controlled VOCs (PTE):
wt% DRE VOC: 76,164 scf/hr x 1/379 scf/lb-mole x 24.49 lb/lb-mole 32.88% x 0% = lb/hr

1618.30 lb/hr x 8760 hr/yr x 1 ton/2000 lb = TPY

Controlled VOCs (Allowable):
wt% DRE VOC: 76,164 scf/hr x 1/379 scf/lb-mole x 24.49 lb/lb-mole 32.88% x 98% = lb/hr

32.37 lb/hr x 8760 hr/yr x 1 ton/2000 lb = TPY 32.37

141.76 x 

## CRITERIA POLLUTANT EMISSIONS a

x 1618.30

7088.13

### FBIR Iron Woman and Yellow Wolf Pad Associated Wells: Iron Woman 21X-10-1, 21X-10-2, 21 X-10-3, Yellow Wolf 11-10-1, 11-10-2, 11-10-3



## Treater Flare 

# XTO Energy, Inc.

Controlled HAPs (PTE):

Using E&P Tanks Run: wt% DRE TPY Benzene 76,164 scf/hr x x 1/379 scf/lb-mole x 24.49 lb/lb-mol x 0.08% x 0% = 3.76 lb/hr 16.45 E-Benzene 76,164 scf/hr x x 1/379 scf/lb-mole x 24.49 lb/lb-mol x 0.00% x 0% = 0.15 lb/hr 0.67

Toluene 76,164 scf/hr x x 1/379 scf/lb-mole x 24.49 lb/lb-mol x 0.03% x 0% = 1.66 lb/hr 7.26 n-Hexane 76,164 scf/hr x x 1/379 scf/lb-mole x 24.49 lb/lb-mol x 0.74% x 0% = 36.39 lb/hr 159.39

Xylene 76,164 scf/hr x x 1/379 scf/lb-mole x 24.49 lb/lb-mol x 0.01% x 0% = 0.62 lb/hr 2.72 2,2,4-Trimethylpentane 76,164 scf/hr x x 1/379 scf/lb-mole x 24.49 lb/lb-mol x 0.09% x 0% = 4.47 lb/hr 19.57 Formaldehyde 76,164 scf/hr 7.50E-02 lb/MMscf = 0.01 lb/hr 0.03

` 47.05 lb/hr x 8760 hr/yr x 1 ton/2000 lb = TPY

Controlled HAPs (Allowable):

Using E&P Tanks Run: wt% DRE TPY Benzene 76,164 scf/hr x x 1/379 scf/lb-mole x 24.49 lb/lb-mol x 0.08% x 98% = 0.08 lb/hr 0.33 E-Benzene 76,164 scf/hr x x 1/379 scf/lb-mole x 24.49 lb/lb-mol x 0.00% x 98% = 0.00 lb/hr 0.01

Toluene 76,164 scf/hr x x 1/379 scf/lb-mole x 24.49 lb/lb-mol x 0.03% x 98% = 0.03 lb/hr 0.15 n-Hexane 76,164 scf/hr x x 1/379 scf/lb-mole x 24.49 lb/lb-mol x 0.74% x 98% = 0.73 lb/hr 3.19

Xylene 76,164 scf/hr x x 1/379 scf/lb-mole x 24.49 lb/lb-mol x 0.01% x 98% = 0.01 lb/hr 0.05 2,2,4-Trimethylpentane 76,164 scf/hr x x 1/379 scf/lb-mole x 24.49 lb/lb-mol x 0.09% x 98% = 0.09 lb/hr 0.39 Formaldehyde 76,164 scf/hr x 7.50E-02 lb/MMscf / 1000000 scf/MMscf = 0.01 lb/hr 0.03

` 0.95 lb/hr x 8760 hr/yr x 1 ton/2000 lb = TPY =

=

4.15 =

= =

=

= =

=

=

206.08

=

=

=

=

### FBIR Iron Woman and Yellow Wolf Pad Associated Wells: Iron Woman 21X-10-1, 21X-10-2, 21 X-10-3, Yellow Wolf 11-10-1, 11-10-2, 11-10-3



## Treater Flare 

# XTO Energy, Inc.

Uncontrolled Nox (PTE):

NOx: 76,164 scf/hr x 1,402 Btu/scf x x 0.068 lb/MMBtu = 7.26 lb/hr

7.26 lb/hr x 8760 hr/yr x 31.79 TPY

NOx Created by Combustion (Actual):

NOx: 76,164 scf/hr x 1,402 Btu/scf x x 0.068 lb/MMBtu = 7.26 lb/hr

7.26 lb/hr x 8760 hr/yr x 31.79 TPY

Controlled H2S (PTE):
wt% DRE H 2 S: 76,164 scf/hr x 1/379 scf/lb-mole x 24.49 lb/lb-mole 0.00% x 0% = l b/hr

0.00 lb/hr x 8760 hr/yr x 1 ton/2000 lb = TPY

Controlled H2S (Actual):
wt% DRE H 2 S: 76,164 scf/hr x 1/379 scf/lb-mole x 24.49 lb/lb-mole 0.00% x 98% = lb/hr

0.00 lb/hr x 8760 hr/yr x 1 ton/2000 lb = TPY 0.00 = 1 Mmbtu/1,000,000 Btu

1 ton/2000 lb =

x 0.00

0.00 1 ton/2000 lb 1 Mmbtu/1,000,000 Btu

x

0.00

### FBIR Iron Woman and Yellow Wolf Pad Associated Wells: Iron Woman 21X-10-1, 21X-10-2, 21 X-10-3, Yellow Wolf 11-10-1, 11-10-2, 11-10-3



## Treater Flare 

# XTO Energy, Inc.

SO2 Created by Combustion (PTE):
wt% DRE SO 2 76,164 scf/hr x 1/379 scf/lb-mole x 24.49 lb/lb-mole 0.00% x 0% = l b/hr

0.00 lb/hr x 8760 hr/yr x 1 ton/2000 lb = TPY

SO2 Created by Combustion (Actual):
wt% DRE SO 2 76,164 scf/hr x 1/379 scf/lb-mole x 24.49 lb/lb-mole 0.00% x 98% = lb/hr

0.00 lb/hr x 8760 hr/yr x 1 ton/2000 lb = TPY

CO Created by Combustion (PTE):

CO: 76,164 scf/hr x 1,402 Btu/scf x x 0.370 lb/MMBtu = 39.50 lb/hr

39.50 lb/hr x 8760 hr/yr x 172.99 TPY

CO Created by Combustion (Actual):

CO: 76,164 scf/hr x 1,402 Btu/scf x x 0.370 lb/MMBtu = 39.50 lb/hr

39.50 lb/hr x 8760 hr/yr x 172.99 TPY 1 Mmbtu/1,000,000 Btu 0.00

= 1 ton/2000 lb x

1 Mmbtu/1,000,000 Btu

1 ton/2000 lb x

= 0.00

0.00

0.00

### FBIR Iron Woman and Yellow Wolf Pad Associated Wells: Iron Woman 21X-10-1, 21X-10-2, 21 X-10-3, Yellow Wolf 11-10-1, 11-10-2, 11-10-3



## Treater Flare 

# XTO Energy, Inc.

PM Created by Combustion (PTE):

PM: 76,164 scf/hr x 7.6 = 0.58 lb/hr

0.58 lb/hr x 8760 hr/yr x 2.54 TPY

PM Created by Combustion (Actual):

PM: 76,164 scf/hr x 7.6 = 0.58 lb/hr

0.58 lb/hr x 8760 hr/yr x 2.54 TPY 1 ton/2000 lb

a NOx, SO2, PM, & CO emission factors are from AP-42 Table 13.5-1 and Table 1.4-2 (Emission Factors for Flare Operations and Natural Gas Combustion). lb/1,000,000 scf

1 ton/2000 lb = = lb/1,000,000 scf

### FBIR Iron Woman and Yellow Wolf Pad Associated Wells: Iron Woman 21X-10-1, 21X-10-2, 21 X-10-3, Yellow Wolf 11-10-1, 11-10-2, 11-10-3



## Treater Flare 

# XTO Energy, Inc.

CO2 (PTE):

CO2 Entrained in the Produced Gas:

DRE CO2: 76,164 scf/hr x 1/379 scf/lb-mole x 24.49 lb/lb-mole 1.02% x 0% = lb/hr

50.29 lb/hr x 8760 hr/yr x 1 ton/2000 lb = 220.28 TPY CO2 Created by Combustion:

CO2: 76,164 scf/hr x 120,000.0 = 9139.65 lb/hr

` 9139.65 lb/hr x 8760 hr/yr x 40031.67 TPY

40251.95 TPY

CO2 (Actual):

CO2 Entrained in the Produced Gas: wt% DRE CO2: 76,164 scf/hr x 1/379 scf/lb-mole x 24.49 lb/lb-mole 1.02% x 0% = lb/hr

50.29 lb/hr x 8760 hr/yr x 1 ton/2000 lb = 220.28 TPY CO2 Created by Combustion:
`

CO2: 76,164 scf/hr x 120,000.0 = 9139.65 lb/hr

` 9139.65 lb/hr x 8760 hr/yr x 40031.67 TPY

40251.95 TPY 50.29 1 ton/2000 lb = x 50.29

Total CO2 Emitted (Allowable): 1 ton/2000 lb = lb/1,000,000 scf

lb/1,000,000 scf Total CO2 Emitted (PTE):

x 

## REGULATED GREENHOUSE GAS EMISSIONS b

### FBIR Iron Woman and Yellow Wolf Pad Associated Wells: Iron Woman 21X-10-1, 21X-10-2, 21 X-10-3, Yellow Wolf 11-10-1, 11-10-2, 11-10-3



## Treater Flare 

# XTO Energy, Inc.

Controlled CH4 (PTE):

wt% DRE CH4: 76,164 scf/hr x 1/379 scf/lb-mole x 24.49 lb/lb-mole 43.11% x 0% = lb/hr

2121.75 lb/hr x 8760 hr/yr x 1 ton/2000 lb = TPY

Controlled CH4 (Actual):

wt% DRE CH4: 76,164 scf/hr x 1/379 scf/lb-mole x 24.49 lb/lb-mole 43.11% x 98% = lb/hr

42.43 lb/hr x 8760 hr/yr x 1 ton/2000 lb = TPY 2121.75

9293.26 x

x 42.43

185.87

### FBIR Iron Woman and Yellow Wolf Pad Associated Wells: Iron Woman 21X-10-1, 21X-10-2, 21 X-10-3, Yellow Wolf 11-10-1, 11-10-2, 11-10-3



## Treater Flare 

# XTO Energy, Inc.

N2O Created by Combustion (PTE):

N2O: 76,164 scf/hr x 2.2 = 0.17 lb/hr

0.17 lb/hr x 8760 hr/yr x 0.04 TPY

N2O Created by Combustion (Actual):

N2O: 76,164 scf/hr x 2.2 = 0.17 lb/hr

0.17 lb/hr x 8760 hr/yr x 0.04 TPY

b CO2 and N2O emission factors are from AP-42 Table 1 .4-2 1 ton/2000 lb =

(Emission Factors for Natural Gas Combustion). 1 ton/2000 lb =

lb/1,000,000 scf lb/1,000,000 scf3,000,000 Btu/hr This burner rating reflects the combined size of al l of the proposed heater treater burners at the fac ility.

NOx: 0.10 lb/MMBtu x 3.00 MMBtu/hr = 0.294 lb/hr

0.2941 lb/hr x 8,760 hr/yr x 1 ton / 2000 lb = 1.288 TPY

CO: 0.08 lb/MMBtu x 3.00 MMBtu/hr = 0.247 lb/hr

0.25 lb/hr x 8,760 hr/yr x 1 ton / 2000 lb = 1.082 TPY

SO2: 5.88E-04 lb/MMBtu x 3.00 MMBtu/hr = 0.002 lb/hr

1.76E-03 lb/hr x 8,760 hr/yr x 1 ton / 2000 lb = 0.008 TPY

PM: 0.01 lb/MMBtu x 3.00 MMBtu/hr = 0.022 lb/hr

0.02 lb/hr x 8,760 hr/yr x 1 ton / 2000 lb = 0.098 TPY

VOC: 0.01 lb/MMBtu x 3.00 MMBtu/hr = 0.016 lb/hr

0.02 lb/hr x 8,760 hr/yr x 1 ton / 2000 lb = 0.071 TPY

HAP: 0.002 lb/MMBtu x 3.00 MMBtu/hr = 0.006 lb/hr

5.56E-03 lb/hr x 8,760 hr/yr x 1 ton / 2000 lb = 0.024 TPY

CO2 117.647 lb/MMBtu x 3.00 MMBtu/hr = 352.941 lb/hr

3.53E+02 lb/hr x 8,760 hr/yr x 1 ton / 2000 lb = 1,545.882 TPY

CH4: 0.007 lb/MMBtu x 3.00 MMBtu/hr = 0.020 lb/hr

1.98E-02 lb/hr x 8,760 hr/yr x 1 ton / 2000 lb = 0.087 TPY

N2O: 0.001 lb/MMBtu x 3.00 MMBtu/hr = 0.004 lb/hr

3.97E-03 lb/hr x 8,760 hr/yr x 1 ton / 2000 lb = 0.017 TPY

NOx TPY

CO TPY

SO2 TPY

PM TPY

VOC TPY

HAP TPY

CO2 TPY

CH4 TPY

N2O TPY 

### XTO Energy, Inc.

1545.88

0.09

0.02 1.08

0.07

0.02 0.01

0.10 FBIR Iron Woman and Yellow Wolf Pad Associated Wells: Iron Woman 21X-10-1, 21X-10-2, 21 X-10-3, Yellow Wolf 11-10-1, 11-10-2, 11- 10-3

Heater Treater Burner a

a NOx, CO, CO2, & VOC Emission Factors are from AP-42 Table 1.4-1 and 1.4-2 (Emission Factors for Nitrogen Oxides (N2O) and Methane come from Table C -1 of Subpart W). Burner Rating

1.29Saturation Vapor Molecular Temp + Load Loss Factor (S) Pressure (P) Weight (MW) 460 lb/1000 gal 12.46 x 0.60 x 2.30 x 45.19 / 510.00 = 1.52

LL Truck Load Load Time lb/1,000 gal Rate bbl/hr hrs gal/bbl 1.52 x 180.00 / 1.00 x 42.00 = 11.49

LL Annual Emissions lb/1,000 gal bbl/yr gal/bbl lb/ton TPY 1.52 x 667194.45 x 42.00 / 2000.00 = 21.30 0.17

VOC Emissions Uncontrolled Control % TPY 0.17 100% 0.00 0.00

LL Annual Emissions lb/1,000 gal bbl/yr gal/bbl lb/ton TPY 1.52 x 667194.45 x 42.00 / 2000.00 = 21.30 0.00

HAPs Emissions Uncontrolled Control % TPY 0.00 100% 0.00 0.00

LL Annual Emissions lb/1,000 gal bbl/yr gal/bbl lb/ton TPY 1.52 x 667194.45 x 42.00 / 2000.00 = 21.30 0.22

CO2 Emissions Uncontrolled Control % TPY 0.22 100% 0.00 0.00

LL Annual Emissions lb/1,000 gal bbl/yr gal/bbl lb/ton TPY 1.52 x 667194.45 x 42.00 / 2000.00 = 21.30 3.60

CH4 Emissions Uncontrolled Control % TPY 3.60 100% 0.00 0.00 

### FBIR Iron Woman and Yellow Wolf Pad Associated Wells: Iron Woman 21X-10-1, 21X-10-2, 21 X-10-3, Yellow Wolf 11-10-1, 11-10-2, 11-10-3



## Truck Loadout Emission Calculation

Total Gas Emissions lb/hr

Uncontrolled C3+ VOC tpy

Uncontrolled

HAPs tpy

Uncontrolled

CO2 tpy

Uncontrolled

CH4 tpy 

# XTO Energy, Inc.Combined Diesel Engines Hours of Operation 8760 Maximum HP Rating 2040 NOx g/hp-hr 2.77E+00 CO g/hp-hr 7.80E-01 SO2 g/hp-hr 4.52E-06 PM g/hp-hr 1.50E-01 VOC g/hp-hr 2.28E-01 HAP g/bh-hr 1.02E-06 CO2 g/bh-hr 2.54E-03 CH4 g/bh-hr 2.10E-02 N2O g/hp-hr 4.20E-03 NOx Control Efficiency 0% CO Control Efficiency 0% SO2 Control Efficiency 0% PM Control Efficiency 0% VOC Control Efficiency 0% HAP Control Efficiency 0% CO2 Control Efficiency 0% CH4 Control Efficiency 0% N2O Control Efficiency 0% Description 

### RICE Input Data

Engine is assumed to operate 8,760 hours per year. Manufacturer's maximum hp rating. Manufacturer's emission factor, actual test results or AP-42 factor in grams per horsepower hour (g/hp -hr) for nitrogen oxides (NOx). Manufacturer's emission factor, actual test results or AP-42 factor in g/hp-hr for carbon monoxide (CO ).

HAP control efficiency of any applicable controls ( NSCR catalyst, AFRC, etc) obtained from manufacture r data or actual test results. Manufacturer's emission factor, actual test results or AP-42 factor in g/hp-hr for total organic compo unds (HAPs).

SO2 control efficiency of any applicable controls ( NSCR catalyst, AFRC, etc) obtained from manufacture r data or actual test results. Manufacturer's emission factor, actual test results or AP-42 factor in g/hp-hr for sulfure dioxide (SO 2).

Manufacturer's emission factor, actual test results or AP-42 factor in g/hp-hr for total organic compo unds (TOC or THC).

NOx control efficiency of any applicable controls ( NSCR catalyst, AFRC, etc) obtained from manufacture r data or actual test results. CO control efficiency of any applicable controls (N SCR catalyst, AFRC, etc) obtained from manufacturer data or actual test results.

VOC control efficiency of any applicable controls ( NSCR catalyst, AFRC, etc) obtained from manufacture r data or actual test results. Manufacturer's emission factor, actual test results or AP-42 factor in g/hp-hr for sulfure dioxide (PM ).

PM control efficiency of any applicable controls (N SCR catalyst, AFRC, etc) obtained from manufacturer data or actual test results. Manufacturer's emission factor, actual test results or AP-42 factor in g/hp-hr for total organic compo unds (CO2). Manufacturer's emission factor, actual test results or AP-42 factor in g/hp-hr for total organic compo unds (CH4).

CO2 control efficiency of any applicable controls ( NSCR catalyst, AFRC, etc) obtained from manufacture r data or actual test results. Manufacturer's emission factor, actual test results or AP-42 factor in g/hp-hr for total organic compo unds (N2O).

N2O control efficiency of any applicable controls ( NSCR catalyst, AFRC, etc) obtained from manufacture r data or actual test results. 

# XTO Energy, Inc.

CH4 control efficiency of any applicable controls ( NSCR catalyst, AFRC, etc) obtained from manufacture r data or actual test results.ENGINES

2040 MAX HP 0% NOx DRE 0% CO DRE 0% VOC DRE 0% SO2 DRE 0% HAP DRE 0% PM DRE ##### #### ##### #### ### 100.00%

NOx: 2.77E+00 g/HP-HR 2040 HP x 1 lb / 453.6 grams = 1.25E+01 lb/hr x 8760 hr/yr x 1 ton / 2000lb = 5.46E+01 NOx TPY

CO: 7.80E-01 g/HP-HR 2040 HP x 1 lb / 453.6 grams = 3.51E+00 lb/hr x 8760 hr/yr x 1 ton / 2000lb = 1.54E+01 CO TPY

SO2: 4.52E-06 g/HP-HR 2040 HP x 1 lb / 453.6 grams = 2.03E-05 lb/hr x 8760 hr/yr x 1 ton / 2000lb = 8.90E-05 SO2 TPY

PM: 1.50E-01 g/HP-HR 2040 HP x 1 lb / 453.6 grams = 6.75E-01 lb/hr x 8760 hr/yr x 1 ton / 2000lb = 2.95E+00 PM TPY

VOC: 2.28E-01 g/HP-HR 2040 HP x 1 lb / 453.6 grams = 1.03E+00 lb/hr x 8760 hr/yr x 1 ton / 2000lb = 4.49E+00 VOC TPY

HAP: 1.02E-06 g/HP-HR 2040 HP x 1 lb / 453.6 grams = 4.59E-06 lb/hr x 8760 hr/yr x 1 ton / 2000lb = 2.01E-05 HCHO TPY

CO2: 2.54E-03 g/HP-HR 2040 HP x 1 lb / 453.6 grams = 1.14E-02 lb/hr x 8760 hr/yr x 1 ton / 2000lb = 4.99E-02 CO2

CH4: 2.10E-02 g/HP-HR 2040 HP x 1 lb / 453.6 grams = 9.44E-02 lb/hr x 8760 hr/yr x 1 ton / 2000lb = 4.14E-01 CH4

N2O: 4.20E-03 g/HP-HR 2040 HP x 1 lb / 453.6 grams = 1.89E-02 lb/hr x 8760 hr/yr x 1 ton / 2000lb = 8.27E-02 N2O x x

x x

x x 

# XTO Energy, Inc.

FBIR Iron Woman and Yellow Wolf Pad Associated Wells: Iron Woman 21X-10-1, 21X-10-2, 21 X-10-3, Yellow Wolf 11-10-1, 11-10-2, 11-10-3 

# Reciprocating Engine Emissions

x

x xXTO Energy, Inc. NSR Synthetic Minor Permit Application XTO211339 

## ATTACHMENT C: REPRESENTATIVE GAS ANALYSIS

## QUESTAR APPLIED TECHNOLOGY

1210 D. Street, Rock Springs, Wyoming 82901 (307) 352-7292

LIMS ID: N/A Description: Jane 11x-20 Analysis Date/Time: 8/30/2011 1:00 PM Field: Lostbridge Analyst Initials: AST ML#: XTO Instrument ID: Instrument 1 GC Method: Quesbtex Data File: QPC73.D Date Sampled: 8/24/2011

Component Mol% Wt% LV%

Methane 65.8105 43.1118 54.9906 Ethane 14.7115 18.0637 19.4481 Propane 8.4823 15.2736 11.5292 Isobutane 1.1052 2.6230 1.7833 n-Butane 3.4281 8.1362 5.3312 Neopentane 0.0052 0.0152 0.0097 Isopentane 0.6395 1.8841 1.1547 n-Pentane 0.9259 2.7278 1.6541 2,2-Dimethylbutane 0.0048 0.0169 0.0099 2,3-Dimethylbutane 0.0447 0.1571 0.0902 2-Methylpentane 0.1557 0.5477 0.3186 3-Methylpentane 0.0847 0.2979 0.1704 n-Hexane 0.2101 0.7394 0.4261 Heptanes 0.3050 1.1676 0.6006 Octanes 0.0396 0.1837 0.0965 Nonanes 0.0125 0.0618 0.0313 Decanes plus 0.0012 0.0071 0.0037 Nitrogen 3.4649 3.9635 1.8738 Carbon Dioxide 0.5686 1.0219 0.4780 Oxygen 0.0000 0.0000 0.0000 Hydrogen Sulfide 0.0000 0.0000 0.0000 Total 100.0000 100.0000 100.0000 Global Properties Units Gross BTU/Real CF 1401.5 BTU/SCF at 60°F and14.73 psi a Sat.Gross BTU/Real CF 1378.5 BTU/SCF at 60°F and14.73 psia Gas Compressibility (Z) 0.9952 Specific Gravity 0.8476 air=1 Avg Molecular Weight 24.490 gm/mole Propane GPM 2.324682 gal/MCF Butane GPM 1.438725 gal/MCF Gasoline GPM 0.892199 gal/MCF 26# Gasoline GPM 1.971372 gal/MCF Total GPM 4.656794 gal/MCF Base Mol% 99.883 %v/v

Sample Temperature: 74 °F Sample Pressure: 34 psig H2SLength of Stain Tube N/A ppmComponent Mol% Wt% LV% Benzene 0.0239 0.0763 0.0330 Toluene 0.0090 0.0337 0.0148 Ethylbenzene 0.0007 0.0031 0.0014 M&P Xylene 0.0024 0.0102 0.0045 O-Xylene 0.0006 0.0024 0.0010 2,2,4-Trimethylpentane 0.0195 0.0908 0.0483 Cyclopentane 0.0000 0.0000 0.0000 Cyclohexane 0.0382 0.1314 0.0642 Methylcyclohexane 0.0378 0.1515 0.0749 Description: Jane 11x-20

GRI GlyCalc Information

Component Mol% Wt% LV% Carbon Dioxide 0.5686 1.0219 0.4780 Hydrogen Sulfide 0.0000 0.0000 0.0000 Nitrogen 3.4649 3.9635 1.8738 Methane 65.8105 43.1118 54.9906 Ethane 14.7115 18.0637 19.4481 Propane 8.4823 15.2736 11.5292 Isobutane 1.1052 2.6230 1.7833 n-Butane 3.4281 8.1362 5.3312 Isopentane 0.6447 1.8993 1.1644 n-Pentane 0.9259 2.7278 1.6541 Cyclopentane 0.0000 0.0000 0.0000 n-Hexane 0.2101 0.7394 0.4261 Cyclohexane 0.0382 0.1314 0.0642 Other Hexanes 0.2899 1.0196 0.5891 Heptanes 0.1766 0.6839 0.3654 Methylcyclohexane 0.0378 0.1515 0.0749 2,2,4 Trimethylpentane 0.0195 0.0908 0.0483 Benzene 0.0239 0.0763 0.0330 Toluene 0.0090 0.0337 0.0148 Ethylbenzene 0.0007 0.0031 0.0014 Xylenes 0.0030 0.0126 0.0055 C8+ Heavies 0.0496 0.2369 0.1246 Subtotal 100.0000 100.0000 100.0000 Oxygen 0.0000 0.0000 0.0000 Total 100.0000 100.0000 100.0000XTO Energy, Inc. NSR Synthetic Minor Permit Application XTO211339 

## ATTACHMENT D: ENGINE MANUFACTURER’S SPECS

# This section of the document has been redacted because it contains copyrighted information. The redacted information

can be viewed from the hard copy of the docket, which is available at the EPA Region 8 Office upon request.XTO Energy, Inc. NSR Synthetic Minor Permit Application XTO211339 

## ATTACHMENT E: NSCR CONTROL MANUFACTURER’S **SPECS**XTO Energy, Inc. NSR Synthetic Minor Permit Application XTO211339 

## ATTACHMENT F: ENCLOSED COMBUSTOR **MANUFACTURER’S SPECS**CIMARRON ENERGY INC.

Home Office: 1-(580) 338-5496 FAX 1-(580) 338-08 85 P.O. Box 1406, Guymon, Oklahoma 73942 Administrative Office: 1-(405) 928-7373 FAX 1-(4 05) 928-7380 P.O. Box 722110, Norman, Oklahoma 73070 

# EMISSION CONTROL DEVICES (ECD)

Cimarron Energy Tank VOC Emission Control Devices a re enclosed combustors that are low maintenance with safe reliable operati on, user friendly, easy to install, and highly efficient. These units are eng ineered to capture and combust VOC emissions from the Oil/Condensate Production Ta nks with clean efficient destruction. Cimarron ECDs have been independently tested and certified to exceed the strict EPA requirements with a 99% destr uction rate.

Specifications on the next page.

Auto Ignition systems also available.

# Specifications

24”D x 8’.5”L ECD 30”D x 8’.5”L ECD Capacity: 8 mcf/d @ 10 oz. Capacity: 11mcf/d @ 10oz. MAWP: Atmospheric MAWP: Atmospheric MMBTU/hr: .7 MMBTU/hr. MMBTU/hr: 1 MMBTU/hr. Number of Jets: 64 Number of Jets: 88 Flame Cell: 24” Flame Cell: 30” Burner: 16” Burner: 25” Backdraft: 2” or 3” Inline Wenco Backdraft: 2” or 3” Inline Wenco Inlet Connection: 3” NPT Inlet Connection: 3” NPT

48”D x 12’L ECD 60”D x 13’L ECD Capacity: 26 mcf/d @ 10 oz. Capacity: 60 mcf/d @ 10 oz. MAWP: Atmospheric MAWP: Atmospheric MMBTU/hr: 2 MMBTU/hr. MMBTU/hr: 5 MMBTU/hr. Number of Jets: 210 Number of Jets: 440 Flame Cell: 48” Flame Cell: 60” Burner: 34” Burner: 42” Backdraft: 2” or 3” Inline Wenco Backdraft: 3” Inline Wenco Inlet Connection: 3” NPT Inlet Connection: 3” NPT



## 48”D x 25’L HV ECD Capacity: 130 mcf/d @ 10 oz. MAWP: Atmospheric Number of orfices: 88 Flame Cell: 4) 36” Inlet Connection: 3” NPT Backdraft: 2” or 3” Inline WencoXTO Energy, Inc. NSR Synthetic Minor Permit Application XTO211339 

## ATTACHMENT G: PROCESS FLOW DIAGRAM OF **FACILITY**Gas & Liquids 2-Phase Production Separator(s) (Up to 6 Separators Site Wide, one Separator for each Well) Liquids (Oil & Produced Water) 0.5 MMBTU/HR Heater Treater(s) (Up to 6 Heater Treaters Site

Wide, One for each well)

Oil Produced Water Gas *Gas

Well Head(s) & Pumping Unit(s) (Up to 6 Well Heads & 6 Pumping Units Site Wide, One for each well)

400 bbl Oil Tank(s) (Up to 24 Tanks Site Wide,

Four Tanks for each well) 400 bbl Produced Water Tank(s) (Up to 12 Tanks Site Wide, Two Tanks for each well)

L.A.C.T. Unit(s) (Pipeline Sales) Sales Oil

Water Pump(s) (Up to 12 Water Pumps Site Wide, one

for each Tank) / Pipeline to Disposal Tank Vapors

Produced Water

Enclosed Combustor(s)

(99% DRE of VOC) (Up to 3 Combustors, site wide total) Utility Flare (98% DRE of VOC) Sales Gas Gas Meter (Pipeline Sales)

*Gas from Separator(s) will either be sent to pipel ine sales, or will be flared if we cannot tie into a s ales pipeline or shut in by third party 3 – GENSETS 500KW (680 hp) Diesel Engines (Supplies Electric Power Pumping Unit,

Water Transfer Pumps, Recycle Pumps, and L.A.C.T Units 

### XTO Energy, Inc. Fort Berthold Indian Reservation Process Flow Diagram – Six (6) Well Pad Design

3 – 1000 Gallon Diesel Storage Tanks FuelGas & Liquids 2-Phase Production Separator(s) (Up to 6 Separators Site Wide, one Separator for each Well) Liquids (Oil & Produced Water) 0.5 MMBTU/HR Heater Treater(s) (Up to 6 Heater Treaters Site

Wide, One for each well)

Oil Produced Water Gas *Gas

Well Head(s) & Pumping Unit(s) (Up to 6 Well Heads & 6 Pumping Units Site Wide, One for each well)

400 bbl Oil Tank(s) (Up to 24 Tanks Site Wide,

Four Tanks for each well) 400 bbl Produced Water Tank(s) (Up to 12 Tanks Site Wide, Two Tanks for each well)

L.A.C.T. Unit(s) (Pipeline Sales) Sales Oil

Water Transfer Pump(s) (Up to 12 Water Transfer Pumps Site Wide, One for each Tank) / Pipeline to Disposal Tank Vapors

Produced Water

Enclosed Combustor(s)

(99% DRE of VOC) (Up to 3 Combustors, Site wide total) Utility Flare (98% DRE of VOC)

Sales Gas Gas Meter (Pipeline Sales)

*Gas from the Separator(s) will either be sent to p ipeline sales, or will be flared if we cannot tie into a s ales pipeline or shut in by third party **When VRU is down or being by passed, Tank Vapors are controlled by the Enclosed Combustor(s) VRT (Vapor Recovery Tower) Up to 6 VRTs Site Wide, One for each well. Stable Oil

VRU (Vapor Recovery Unit) Gas

Gas Meter (Pipeline Sales) Gas 3 – GENSETS 500KW (680hp) Diesel Engines (Supplies Electric Power for the

VRU, Pumping Units, Water

Transfer Pumps, Recycle Pumps, and L.A.C.T. Units

3 -1000 gal Diesel Fuel

Tanks Fuel 

### XTO Energy, Inc. Fort Berthold Indian Reservation Process Flow Diagram – Six (6) Well PadXTO Energy, Inc. NSR Synthetic Minor Permit Application XTO211339 

## ATTACHMENT H: PRODUCTION DECLINE CURVE **CALCULATIONS (CONFIDENTIAL)**XTO Energy, Inc. NSR Synthetic Minor Permit Application XTO211339 

## ATTACHMENT I: DIESEL TANK EPA TANKS 4.09D **EMISSIONS SUMMARY**

### TANKS 4.0.9d Emissions Report - Detail Format Tank Indentification and Physical Characteristics

Identification User Identification: 1000 gallon diesel tank City: Williston State: North Dakota Company: XTO Energy Type of Tank: Horizontal Tank Description: 1,000 gallon diesel tank to fuel onsit e diesel generators. Tank throughput is based on en gine fuel consumption.

Tank Dimensions Shell Length (ft): 10.00 Diameter (ft): 4.16 Volume (gallons): 1,000.00 Turnovers: 314.48 Net Throughput(gal/yr): 314,484.00 Is Tank Heated (y/n): N Is Tank Underground (y/n): N

Paint Characteristics Shell Color/Shade: Gray/Medium Shell Condition Good

Breather Vent Settings Vacuum Settings (psig): -0.03 Pressure Settings (psig) 0.03

Meterological Data used in Emissions Calculations: Bismarck, North Dakota (Avg Atmospheric Pressure = 13.86 psia) 

### Page 1 of 6 TANKS 4.0 Report

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### TANKS 4.0.9d Emissions Report - Detail Format Liquid Contents of Storage Tank

Daily Liquid Surf. Temperature (deg F) Liquid Bulk Temp Vapor Pressure (psia) Vapor Mol. Liquid Mass Vapor Mass Mol. Basis for Vapor Pressure Mixture/Component Month Avg. Min. Max. (deg F) Avg. Min. M ax. Weight. Fract. Fract. Weight Calculations

Distillate fuel oil no. 2 All 50.18 39.72 60.64 44.68 0. 0045 0.0031 0.0067 130.0000 188.00 Option 1: VP50 = .0045 VP60 = .0065 

### Page 2 of 6 TANKS 4.0 Report

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### TANKS 4.0.9d Emissions Report - Detail Format Detail Calculations (AP-42)

Annual Emission Calcaulations

Standing Losses (lb): 0.2654 Vapor Space Volume (cu ft): 86.5719 Vapor Density (lb/cu ft): 0.0001 Vapor Space Expansion Factor: 0.0780 Vented Vapor Saturation Factor: 0.9995
Tank Vapor Space Volume: Vapor Space Volume (cu ft): 86.5719 Tank Diameter (ft): 4.1600 Effective Diameter (ft): 7.2797 Vapor Space Outage (ft): 2.0800 Tank Shell Length (ft): 10.0000

Vapor Density Vapor Density (lb/cu ft): 0.0001 Vapor Molecular Weight (lb/lb-mole): 130.0000 Vapor Pressure at Daily Average Liquid Surface Temperature (psia): 0.0045 Daily Avg. Liquid Surface Temp. (deg. R): 509.846 6 Daily Average Ambient Temp. (deg. F): 41.5958 Ideal Gas Constant R (psia cuft / (lb-mol-deg R)): 10.731 Liquid Bulk Temperature (deg. R): 504.3458 Tank Paint Solar Absorptance (Shell): 0.6800 Daily Total Solar Insulation Factor (Btu/sqft day): 1,276.2450

Vapor Space Expansion Factor Vapor Space Expansion Factor: 0.0780 Daily Vapor Temperature Range (deg. R): 41.8377 Daily Vapor Pressure Range (psia): 0.0036 Breather Vent Press. Setting Range(psia): 0.0600 Vapor Pressure at Daily Average Liquid Surface Temperature (psia): 0.0045 Vapor Pressure at Daily Minimum Liquid Surface Temperature (psia): 0.0031 Vapor Pressure at Daily Maximum Liquid Surface Temperature (psia): 0.0067 Daily Avg. Liquid Surface Temp. (deg R): 509.8466 Daily Min. Liquid Surface Temp. (deg R): 499.3872 Daily Max. Liquid Surface Temp. (deg R): 520.3060 Daily Ambient Temp. Range (deg. R): 24.3583

Vented Vapor Saturation Factor Vented Vapor Saturation Factor: 0.9995 Vapor Pressure at Daily Average Liquid: Surface Temperature (psia): 0.0045 Vapor Space Outage (ft): 2.0800

Working Losses (lb): 1.1569 Vapor Molecular Weight (lb/lb-mole): 130.0000 Vapor Pressure at Daily Average Liquid Surface Temperature (psia): 0.0045 Annual Net Throughput (gal/yr.): 314,484.0000 

### Page 3 of 6 TANKS 4.0 Report

9/29/2011 file://C:\Program Files\Tanks409d\summarydisplay.ht mAnnual Turnovers: 314.4840 Turnover Factor: 0.2621 Tank Diameter (ft): 4.1600 Working Loss Product Factor: 1.0000

Total Losses (lb): 1.4223 

### Page 4 of 6 TANKS 4.0 Report

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### Emissions Report for: Annual

1000 gallon diesel tank - Horizontal Tank Williston, North Dakota 

### TANKS 4.0.9d Emissions Report - Detail Format Individual Tank Emission Totals

Losses(lbs) Components Working Loss Breathing Loss Total Emissions
Distillate fuel oil no. 2 1.16 0.27 1.42 

### Page 5 of 6 TANKS 4.0 Report

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### Page 6 of 6 TANKS 4.0 Report

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