## Oil and Gas Production Facilities

Chapter 6, Section 2 Permitting Guidance

June 1997

Revised November 1998

Revised January 2000

Revised August 2001

Revised July 28, 200 4 (specific guidance for Jonah/Pinedale Anticline Area)

Revised August 2007

Revised March 20 10

This Guidance applies to surface oil and gas production facilities where hydrocarbon fluids are produced,

processed and/ or treated prior to custody transfer from the facility

.

This Guidance does not apply to natural gas

- fired engines unless the engine is used to power a pumping

unit.

The Presumptive BACT permitting requirements under this Guidance apply to facilities with associated

well s spud on/after August 1 , 2010 and to facilities with a modification occurring on/after August 1

,

2010

.

S tart up or modification of a facility may occur prior to obtaining an Air Quality Permit or Waiver only

when the Presumptive BACT permitting require ments under this Guidance are met

. Otherwise, an Air

Quality Permit or Waiver shall be obtained prior to start up or modification of a facility.

For the purposes of this Guidance C DA refers to facilities located in Concentrated Development Areas

.

JPAD refers to facilities located in the Jonah and Pinedale Anticline Development Area

.

STATEWIDE refers to all facilities not located in the C DA or JPAD areas

.

## B L A N K

## Table of Contents

Applicability 1

When is a permit needed 1

Which pollutants are associated with O&G Production Facilities 1

Production Facility Emission Sources 2

O&G Production Facility equipment emission sources 2

BACT & Presumptive BACT (what it is and when to use it) 3

JPAD CDA STATEWIDE Map 4

STATEWIDE P

- BACT permitting requirements 5

Flashing 5

Dehydration Units 6

Scenario 1 6

Scenario 2 7

Determining potential uncontrolled & potential emissions from dehydration units 8

Pneumatic p umps 9

Pneumatic c ontrollers 10

Blow d own & v enting 1 0

Emission s ources without P

- BACT requirements 10

CDA P

- BACT permitting requirements 11

Flashing 11

Dehydration u nits 12

Scenario 1 12

Scenario 2 13

Pneumatic p umps 14

Pneumatic c ontrollers 15

Well c ompletions 15

Produced w ater t anks 16

Blow d own & v enting 17

Emission s ources without P

- BACT requirements 17

JPAD P

- BACT permitting requirements 18

F lashing 18

D ehydration u nits 18

Pneumatic heat trace pumps & other pneumatic pumps 19

Pneumatic controllers 19

Produced water tanks 20

Well completions 20

Blow down & venting 21

Emission s ources without P

- BACT requirements 21

Determining P

- BACT emissions 22

Flashing 22

Dehydration units 24

Kimray glycol pump rates (Table 1) 25

## Table of Contents cont’d

BACT Emission control requirements 26

Flashing e missions 26

Dehydration u nit e missions 27

Sources without P

- BACT e mission c ontrol r equirements 28

Permit Applications 29

A c omplete applications includes ... 29

How to obtain forms 30

When/where to file application 30

Example process diagram & description 31

- 32

Application review process , Public Notice, billing 33

Notice of Installation 34

NOI use as complete application 34

NOI use as e quipment change notification 34

Examples for use of NOI 36

How to obtain NOI form 37

When/where to file NOI form 37

JPAD permit application

- specific requirements 38

AQD Pinedale 1 forms 39

Explanation of 0.6 decline factor 40

Appendix A

- Permit Application Forms 42

AQD

- OG0 Application Identification 44

AQD

- OG0 NOI Identification 45

AQD

- OG00 Checklist for Complete Application 46

AQD

- OG1 Application Cover Sheet 47

AQD

- OG2 Equipment List 48

Equipment List Page 2 49

AQD

- OG3 Storage Tanks, Pressurized Vessels & Pneumatic Pumps 50

AQD

- OG4 Dehydration Units 51

AQD

- OG5 Pumping Unit Engines 52

AQD

- OG6 Emission Summary 53

AQD

- OG7 NOI 54

AQD

- OG8 Multiple Facilities 55

AQD

- OG9 Change of Ownership 56

AQD

- OG10 BACT Cost Analysis Worksheet 57

Appendix B

– Emission Calculations 59

AP

- 42 emission factors 61

Storage tank emissions (flashing, working, breathing losses) 61

Pressurized vessels (separator, treater, FWKO, flash separator, gunbarrel, gas boot) 62

Dehydration units 62

Natural gas

- fired heaters 63

Flares 63

Pneumatic pumps 64

Truck loading 65

Fugitives 66

IC pumping unit engines 67

Mol% to Wt% conversion 67

Appendix C

– Definitions 68

## A cronyms & A bbreviations

For thepurposes of this Guidance C DA refers to facilities located in Concentrated Development Areas

.

JPAD refers to facilities located in the Jonah and Pinedale Anticline Development Area

.

STATEWIDE refers to all facilities not located in the C DA or JPAD areas.

AQD Air Quality Division

API American Petroleum Institute

BACT Best Available Control T echnology

BBL barrel

BPD barrels per day

BTEX Benzene/Toluene/

E thyl

- b enzene/Xylenes

Btu British thermal unit

C6 S2 Chapter 6 Section 2 (of the

WAQSR)

CAA Clean Air Act Amendments of 1990

CDA Concentrated Development Area

CO C arbon M onoxide

EPA Environmental Protection Agency

gpm gallons per minute

H 2 S Hydrogen Sulfide

HAP Hazardous Air Pollutants

HP high pressure

Hp horsepower

JPAD Jonah & Pinedale Anticline

Development Area

lb pound

LP low pressure

MMBtu one million BTUs

MMSCF one million standard cubic feet

(SCF × 10 6 )

(MMSCFD = 1,000,000 SCF per day) MSCF one thousand standard cubic feet

(SCF×1000)

(MSCFD=1000 SCF per day)

NESHAP National Emission Standards for

Hazardous Air Pollutants

NOI Notice of Installation

NOV Notice of Violation

NO X Nitrogen Oxides

NSPS New Source Performance

Standards

NSR New Source Review

pph pounds per hour

PPMV parts per million by volume

PSD Prevention of Significant

Deteriorati on

psi g pounds per square inch gauge

psia pounds per square inch absolute

SCF standard cubic foot

SO 2 Sulfur Dioxide

S/W/B Standing/Working/Breathing losses

TEG Tri

- Ethylene Glycol

TPY Tons per Year

VOC Volatile Organic Compounds

WAQD Wyoming Air Quality Division

WAQSR Wyoming Air Quality Standards

and Regulations

WDEQ Wyoming Department of

Environmental QualityC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 1 of 7 1



## Introduction

The Chapter 6 Section 2 Oil and Gas Production Facilities Permitting Guidance (C6 S2 Guidance)

document serves as a supplement to the Wyoming Air Quality Standards and Regulations ( WAQSR )

Chapter 6 Section 2 New Source Review (NSR) permitting program

. The C6 S2 Guidance applies solely to

the permitting of oil and gas production facilities

.

O btain a copy of the C6 S2 Guidance by contact ing the Wyoming Air Quality Division at (307) 777

- 7391

or (307) 473

- 3475 or do wnload a PDF version from http://deq.state.wy.us/aqd/



## Applicability

If ANY air pollutant will be released to the atmosphere from a new or modified facility, the facility is

subject to WAQSR and the Wyoming Environmental Quality Act.

Owners/operators of ALL regulated air emission sources constructed or modified after May 2 9, 1974

shall comply with the WAQSR Chapter 6, Section 2 permitting requirements.

Failure to comply with Wyoming air quality regulations may result in an enforcement action in the form

of a “Notice of Violation” and penalties of up to $10,000.00 per day

.

To obtain a copy of the WAQSR contact the Wyoming Air Quality Division at (307) 777

- 7391 or download

the PDF version from http://deq.state.wy.us/aqd/

A ir pollutants associated with O& G production facilities are:

Volatile Organic Compounds ( VOC ): H ydrocarbon compounds excluding methane (C

1 ) and ethane (C

2 )

.

VOC s are also referred to as C

3 + compounds

– propane , butane, pentane, hexane, + etc.

Hazardous Air Pollutants ( HAP ): Section 112(b) of the Clean Air Act lists 188 HAPs . HAPs commonly

associated with O&G production are BTEX and n

- hexane (benzene, toluene, ethyl

- benzene, xylenes and

n

- C 6 ).

Nitrogen Oxides ( NO X ): NO X emissions are the result of natural gas combustion.

Carbon Monoxide ( CO ): CO emissions are the result of natural gas combustion.

Hydrogen Sulfide ( H 2 S ): Sour gas and Sulfur Dioxide ( SO 2 ) created when sour gas is combusted.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 2 of 7 1



## Production Facility Emission Sources

O&G production facilities emission sources :

Storage Tanks : Vapors containing regulated air pollutants are released from solution as oil, condensate

and water are transferred from separation equipment to atmospheric storage tank s. These vapors are

called flashing losses

. Vapors evaporated or displaced from tanks are called working and breathing

(also called standing ) losses

.

Dehydration Units : Glycol, usually tri

- ethylene glycol (TEG), is used in dehydration units to absorb water

from wet produced gas. “Lean” TEG contacts the wet gas and absorbs water. The TEG , now considered

“rich ” is routed through a flash separator and/or reboiler for regeneration. Vapors released from the

flash separator and reboiler still vent contain regulated air pollutants.

Pressurized Process Vessel s : Vapors vented from gun barrels, separators, treaters, water knockouts,

gas boots, flash separators, drip pots, etc. contain regulated air pollutants. The discharge lines and

vents from all of these vessels shall be considered when determining emission sources.

Natural Gas

- Fired Equipment : Some of the byproducts of natural gas combustion in process heaters,

boilers, burners, flares, engines, etc. are regulated air pollutants.

Fugitives : All production facilities contain numerous equipment components such as valves, flanges,

threaded connections, tubing connections, open

- ended lines, pump seals, etc which are manufactured

and installed in ways intended to contain gases or liquids. Over time some of them begin to leak.

Unintentional emissions associa ted with leaks are called fugitive emissions

. For purposes of this

Guidance, emissions from components that are improperly designed (e.g. enardo valve s over

pressurizing

, failure of thief hatches to reseat after over pressurizing) or equipment not maintained

properly (e.g.

, thief hatch left open) are not considered to be fugitive emissions.

Pneumatic Pumps & Controllers : The discharge vapors from natural gas

- operated pneumatic

equipment contain regulated air pollutants

.

Truck Loading : Vapors d isplaced from truck tanks during the loading of oil or condensate contains

r egulated air pollutants.

Venting & Blow down : Natural gas and liquids contain regulated air pollutants.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 3 of 7 1



## BACT & Presumptive BACT

Under C6 S2

, all new or modified sources or facilities which may generate regulated air emissions shall

be permitted prior to start up or modification and Best Available Control Technology (BACT) shall be

applied t o reduce or eliminate emissions, with consideration gi ven for technical feasibility and

economical reasonableness. BACT is a process, not an emission limit. Regulation does not set a

minimum emission threshold below which BACT does not need to be considered.

At O&G facilities production rates and associa ted pollutant emissions are usually unknown prior to start

up . T he AQD has tailored a permitting program allowing for the start up or modification of O&G

facilities prior to permitting provided specific emission control requirements are met.

This is the Presumptive BACT permitting process for O&G production facilities

.

Presumptive BACT requirements have been established for emissions associated with:

F lash ing & working/breathing losses from atmospheric storage tanks and pressurized vessels

D ehydration unit process vents

Natural gas

- operated pneumatic equipment

N atural gas

- fired pumping unit engines

If emissions are known prior to construction or modification, a permit shall be obtained PRIOR TO

CONSTRUCTION or MODIFICATION and Presumptive BACT shall be addressed in the application

. Examples include :

Construction of a central tank battery for collecting and processing production from surrounding

existing wells with known production rates ;

Consolidation of multiple existing facilities for which product ion rates have been established;

Installation of a dehydration unit for an existing well with an established gas production rate;

Installation of larger capacity equipment to replace undersized equipment;

Replacement of an emission control system or device with a different system or device.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 4 of 7 1



## Presumptive BACT

Presumptive BACT requirements have been established for three areas

.

C DA Concentrated Development Areas.

JPAD Jonah and Pinedale Anticline Development Area.

STATEWIDE

The CDA is defined by seven counties: Sublette, Lincoln, Uinta, Carbon, Sweetwater, Fremont and

Natrona.

The JPAD area is defined as:

R109W & R110W in T34N

R109W & R110W in T33N

R108W, R109W & R110W in T32N

R108W, R109W & R110W in T31N

R107W, R108W & R109 W in T30N

R107W, R108W & R109W in T29N

R108W & R109W in T28N

R107W, R108W & R109W in T27N

S TATEWIDE refers to all other areas

.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

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## Presumptive BACT Requirements for STATEWIDE F acilities

Flashing

For the purpose of determining flashing emissions a ll vapor streams containing VOC or HAP components

from all storage tanks (e.g., oil, condensate , produced water with oil or condensate carryover ) and all

separation vessels (e.g., gun barrels, production and test separators, production and test treaters

, water

knockouts, gas boots, flash separators, drip pots, etc.) at a facility which are or may be vented to the

atmosphere shall be considered

.

New Facilit ies

Within 60

- days of the First Date of Production ( FDOP )

, flashing emissions containing greater

than or equal to 10 TPY VOC shall be controlled by at least 98%

.

Modified Facilit ies

Within 60

- days of modification, new and existing flashing emissions containing greater than or

equal to 10 TPY VOC shall be controlled by at least 98%

.

New and M odified Facilities

Condensate and oil tanks that are on site for use during emergency or upset conditions, such as

spare tanks at facilities connected to liquids gathering systems, are not subject to the 98%

control requirements

.

The removal of f lashing e missions control devices may be allowed upon approval after one year

if VOC flashing emissions have declined to less than , and are reasonably expected to remain

below 8 TPY.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 6 of 7 1



## Presumptive BACT Requirements for STATEWIDE Facilities cont’d



## Dehydration Units

To meet the P

- BACT requirements for dehydration units o perators must follow

either Scenario 1 or Scenario 2

.

For the purpose of determining emissions from dehydration units, vapor streams containing VOC or HAP

components released from the process vents (reboiler still vents & glycol flash separator vents) of all

dehydration units at a facility which are or may be vented to the atmosphere shall be considered

.



## Scenario 1

New Facilit ies

PAD Facilities

Upon FDOP

, all dehydration unit VOC and HAP emissions shall be controlled by at least 98%.

After one year, combustion units used to achieve the 98% control may be removed upon

approval if

Total potential 1 VOC emissions from all units are less than 6 TPY and

All units are equipped with still vent condensers

.

Single Well Facilit ies

Upon FDOP

, all dehydration units shall be equipped with reboiler still vent condensers . The

condensers may not later be removed.

Within 60

- days of FDOP

, i f total potential uncontrolle d 1 VOC emissions from all units are greater

than or equal to 6 TPY , emissions from all units shall be controlled by at least 98%.

After one year, combustion units used to achieve the 98% control may be removed upon

approval if

Total potential 1 VOC emissio ns from all units are less than 6 TPY and

All units are equipped with still vent condensers

.

Modified Facilit ies

Requirements are the s ame as those for PAD s and s ingle well facilities except use the date of

modification in place of FDOP. Control requirements apply to existing and new dehydration

units.

1 See definitions on Page 8C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 7 of 7 1



## Presumptive BACT Requirements for STATEWIDE Facilities cont’d



## Dehydration Units Scenario 2

New PAD and Single Well Facilit ies

Upon FDOP

, all dehydration units shall be equipped with glycol flash separators and reboiler still

vent condensers

. Removal of t he flash separators and condensers will not be allowed

.

Within 30

- days of FDOP

, if total potential uncontrolled 1 VOC emissions from all dehydration

units are great er than or equal to 8 TPY, at least 98% control of emissions shall be installed and

operational on all units.

After one year, combustion units used to achieve the 98% control may be removed upon

approval if

Total potential 1 VOC emissions from all units ar e less than 8 TPY and

All units are equipped with flash separators and still vent condensers

.

Modified Facilit ies

Upon modification

, glycol flash separators and reboiler still vent condensers shall be installed

and operating on all new and existing dehydration units. Removal of the flash separators and

condensers will not be allowed

.

Within 30

- days of modification

, i f total potential uncontrolled 1 VOC emissions are greater than

or equal to 8 TPY, at least 98% control of emissions shall be install ed and operational on all new

and existing dehydration units.

After one year, combustion units used to achieve the 98% control may be removed upon

approval if

Total potential 1 VOC emissions from all units are less than 8 TPY and

All units are equipped wit h flash separators and still vent condensers

. All Facilities

When a combustion unit is required at a facility for control of flash or dehydration unit

emissions, all non

- condensable still vent vapors shall be collected and routed to the combustion

unit for at least 98% control of VOC and HAP emissions and all glycol flash separator vapors shall

be collected and routed to the combustion unit for at least 98% control of VOC and HAP

emissions and/or used as fuel for process equipment burners.

At facilities wh ere a combustion unit is not required for control of flash or dehydration unit

emissions, all glycol flash separator vapors shall be collected for use as fuel in process

equipment burners. Excess flash vapors that are not used as fuel may be vented to the

atmosphere.

1 See definitions on Page 8C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 8 of 7 1



## Presumptive BACT Requirements for STATEWIDE Facilities cont’d



## Dehydration Units

Potential Uncontrolled VOC emissions shall be determined using GRI

- GLYCalc V3.0 or higher or other

method accepted by the Division and shall be based on the projected, year one, average daily dry gas

throughput rate, maximum circulation rate for the glycol circulation pump(s) i nstalled, average expected

operating parameters for wet gas temperature and pressure, maximum dry gas water content or

number of absorber stages and extended hydrocarbon content of the wet gas from a sample of the wet

gas taken upstream of the dehydration unit contact tower . Flash separators and still vent condensers,

limited operat ing hours and limited glycol circulation rates shall not be considered when determining

potential uncontrolled emissions.

Still vent condensers shall consist of equipment engin eered and designed to achieve maximum

condensation of the condensable components in the still vent vapors by providing adequate

temperature differentials between the condenser outlet and still vent stream. St ill vent pipes shall not

be considered condense rs.

Potential emissions for determining combustion device removal after one year shall be calculated using

GRI

- GLYCalc V3.0 or higher or other method accepted by the Division based on the most recent 30

- days

of normal gas production rates, actual average wet gas temperature and pressure, actual water content

of the dried gas or number of absorber stages, “worst case” operating parameters of the glycol flash

separator and still vent condenser.

“Worst case” flash separator and condenser parameters are:

1 ) maximum glycol flash separator operating pressure

2) lowest glycol flash separator operating temperature

3) maximum still vent condenser outlet temperature

4) maximum still vent condenser outlet pressure

5) all vapors from flash separator are vented

Actual operating parameters for glycol flash separator s and still vent condenser s may be used upon

approval. Limited operating hours and limited glycol circulation rates shall not be considered when

determining potential emissions.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 9 of 7 1



## Presumptive BACT Requirements for STATEWIDE Facilities cont’d



## Pneumatic Pumps

New Facilit ies

PAD Facilit ies

Upon FDOP

, VOC and HAP emissions associated with the discharge streams of all natural

gas

- operated pneumatic pumps shall be controlled by at least 98% or the pump

discharge streams shall be routed into a closed loop system (e.g.

, sales line, collection

line, fuel supply line ).

Single Well Facilities

Within 60

- days of FDOP

, At sites with combustion units installed for th e control of flash or dehydration

unit emissions :

VOC and HAP emissions associated with the discharge streams from

natural gas

- operated pneumatic pumps shall be control led by at least

98% by rout ing the pump discharge streams into the c ombustion unit or

th e discharge streams shall be routed into a closed loop system.

At sites without combustion units installed for the control of flash or

dehydration unit emissions :

Pneumatic pumps ( other than those for heat trace/heat medium/hot

glycol circulation ) shall b e solar, electric or air

- driven pumps in lieu of

natural gas

- operated p neumatic pumps . Wherever possible, heat

trace/heat medium/hot glycol circulation pumps shall be solar

operated, electric or air

- driven.

Modified Facilit ies

Requirements are the s ame as above except include all new and existing pneumatic pumps and

use the date of modification in place of FDOP.

New and Modified Facilit ies

At sites where pneumatic pump emissions are controlled by a combustion unit used for the

control of flash or dehyd ration unit emissions, control of the pneumatic pump emissions will be

evaluated upon request for removal of the combustion unit. (see F lashing , Page 5 )C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 10 of 7 1



## Presumptive BACT Requirements for STATEWIDE Facilities cont’d



## Pneumatic Controllers

New Facilities

Upon FDOP, natural gas

- operated pneumatic controllers shall be low* or no

- bleed controllers or

the controller discharge streams shall be routed into a closed loop system.

Modified Facilities

Upon modification, new natural gas

- operated pneumatic controllers shall be low or no

- bleed

controllers or the controller discharge streams shall be routed into a closed loop system.

Within 60

- days of modification, e xisting natural gas

- operated pneumatic controllers shall be

replaced by or converted to low or no

- bleed controllers or the discharge streams of the existing

natural gas

- operated controllers shall be routed in to a closed loop system.



## Blow down/Venting

Best M anagement P ractices (BMP) and i nformation gathering requirements will be incorporated into

permits for new and modified facilities.

BMP : During manual and automated blow down/venting episodes associated with liquids

unloading, wellbore depressurization in preparation for maintenance or repair, hydrate clearing,

emergency operations, equipment depressurization, etc.

, associated VOC and HAP emissions

shall be minimized to the extent practicable. During manual blow down/venting, personnel shall

remain on site to ensure minimal gas venting occurs.

Information Gathering: Specific recordkeeping and reporting requirements will be established

during the permitting process and will include estimates of associated regulated air pollutants,

reasons for episodes, durations of episodes, steps take n to minimize emissions and descriptions

of emission estimation methods.



## Emission sources without Presumptive BACT requirements

For uncontrolled sources emitting greater than or equal to 8 TPY VOC or greater than or equal to 5 TPY

total HAP s that do n ot have P

- BACT requirements

, a BACT analysis shall be filed with the permit

application for the associated facility. * low bleed devices vent less than 6 cfhC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 11 of 7 1



## Presumptive BACT Requirements for CDA Facilities

Flashing

For the purpose of determining flashing emissions all vapor streams containing VOC or HAP components

from all storage tanks (e.g., oil, condensate, produced water with oil or condensate carryover) and all

separation vessels (e.g., gun barrels, production a nd test separators, production and test treaters, water

knockouts, gas boots, flash separators, drip pots, etc.) at a facility which are or may be vented to the

atmosphere shall be considered.

New Facilities

PAD Facilities

Upon FDOP

, VOC and HAP flashi ng emissions shall be controlled by at least 98%.

Single Well Facilities

Within 60

- days of FDOP

, f lash ing emissions containing greater than or equal to 8 TPY

VOC shall be controlled by at least 98%.

Modified Facilit ies

PAD Facilities

Upon modification

, all new and existing VOC and HAP flash emissions shall be controlled

by at least 98%.

Single Well Facilities

Within 60

- days of modification

, all new and existing flashing emissions containing

greater than or equal to 8 TPY VOC shall be controlled by at l east 98%.

New and Modified Facilit ies

Condensate and oil tanks that are on site for use during emergency or upset conditions, such as

spare tanks at facilities connected to liquids gathering systems, are not subject to the 98%

control requirements.

The removal of f lashing emissions control devices may be allowed upon approval after one year

if VOC flashing emissions have declined to less than , and are reasonably expected to remain

below 8 TPY

.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 12 of 7 1



## Presumptive BACT Requirements for CDA Facilities cont’d



## Dehydration Units

To meet the P

- BACT requirements for dehydration units operators must follow

either Scenario 1 or Scenario 2

.

For the purpose of determining emissions from dehydration units, vapor streams containing VOC or HAP

components released from the process vents (reboiler still vents & glycol flash separator vents) of all

dehydration units at a facility which are or may be vented to the atmosphere shall be considered.



## Scenario 1

New Facilit ies

PAD Facilities

Upon FDOP, all dehydration unit VOC and HAP emissions shall be controlled by at least 98%.

After one year, combustion units used to achieve the 98% control may be removed upon

approval if

Total potential 1 VOC emissions from all units are less than 6 TPY a nd

All units are equipped with still vent condensers

.

Single Well Facilit ies

Upon FDOP, all dehydration units shall be equipped with reboiler still vent condensers. Removal

of t he condensers will not be allowed

.

Within 60

- days of FDOP, if total potentia l uncontrolled 1 VOC emissions from all units are greater

than or equal to 6 TPY, emissions from all units shall be controlled by at least 98%.

After one year, combustion units used to achieve the 98% control may be removed upon

approval if

Total potential 1 VOC emissions from all units are less than 6 TPY and

All units are equipped with still vent condensers

.

Modified Facilit ies

Requirements are the same as those for PADs and single well facilities except use the date of

modification in place of FDOP. Control requirements apply to existing and new dehydration

units.

1 See definitions on Page 8C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 13 of 7 1



## Presumptive BACT Requirements for CDA Facilities cont’d



## Dehydration Units Scenario 2

New PAD and Single Well Facilities

Upon FDOP, all dehydration units shall be equipped with glycol flash separators and reboiler still

vent condensers. Removal of the flash separators and condensers will not be allowed

.

Within 30

- days of FDOP, if total potential uncontrolled 1 VOC emission s from all dehydration

units are greater than or equal to 8 TPY, at least 98% control of emissions shall be installed and

operational on all units.

After one year, combustion units used to achieve the 98% control may be removed upon

approval if

Total pote ntial 1 VOC emissions from all units are less than 8 TPY and

All units are equipped with flash separators and still vent condensers

.

Modified Facilit ies

Upon modification, glycol flash separators and reboiler still vent condensers shall be installed

and o perating on all new and existing dehydration units. Removal of the flash separators and

still vent condensers will not be allowed

.

Within 30

- days of modification, if total potential uncontrolled 1 VOC emissions are greater than

or equal to 8 TPY, at lea st 98% control of emissions shall be installed and operational on all new

and existing dehydration units.

After one year, combustion units used to achieve the 98% control may be removed upon

approval if

Total potential 1 VOC emissions from all units are le ss than 8 TPY and

All units are equipped with flash separators and still vent condensers

. All Facilities

When a combustion unit is required at a facility for control of flash or dehydration unit

emissions , all non

- condensable still vent vapors shall be col lected and routed to the combustion

unit for at least 98% control of VOC and HAP emissions and all glycol flash separator vapors shall

be collected and routed to the combustion unit for at least 98% control of VOC and HAP

emissions and/or used as fuel for process equipment burners.

At facilities where a combustion unit is not required for control of flash or dehydration unit

emissions , all glycol flash separator vapors shall be collected for use as fuel in process

equipment burners. Excess flash vapors that are not used as fuel may be vented to the

atmosphere

.

1 See definitions on Page 8C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 14 of 7 1



## Presumptive BACT Requirements for CDA Facilities cont’d



## Pneumatic Pumps

New Facilit ies

PAD Facilit ies

Upon FDOP, VOC and HAP emissions associated with the discharge streams of all natural

gas

- operated pneumatic pumps shall be controlled by at least 98% or the pump

discharge streams shall be routed into a closed loop system (e.g., sales line, collection

lin e, fuel supply line).

Single Well Facilities

Within 60

- days of FDOP,

At sites with combustion units installed for the control of flash or dehydration

unit emissions:

VOC and HAP emissions associated with the discharge streams from

natural gas

- operated pneumatic pumps shall be controlled by at least

98% by routing the pump discharge streams into the combustion unit or

the discharge streams shall be routed into a closed loop system.

At sites without combustion units installed for the control of flash or

dehydration unit emissions:

Pneumatic pumps ( other than heat trace/heat medium/hot glycol

circulation ) shall be solar, electric or air

- driven pumps in lieu of natural

gas

- operated pneumatic pumps. Wherever possible, heat trace/heat

medium/hot glycol circu lation pumps shall be solar

- operated, electric or

air

- driven.

Modified Facilit ies

Requirements are the s ame as above except include all new and existing pneumatic pumps and

use the date of modification in place of FDOP.

New and Modified Facilit ies

At sites where pneumatic pump emissions are controlled by a combustion unit used for the

control of flash or dehydration unit emissions, control of the pneumatic pump emissions will be

evaluated upon request for removal of the combustion unit. (see Flashing

, Page 11 )C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 15 of 7 1



## Presumptive BACT Requirements fo r CDA Facilities cont’d



## Pneumatic Controllers

New Facilit ies

Upon FDOP, natural gas

- operated pneumatic controllers shall be low* or no

- bleed controllers or

the controller discharge streams shall be routed into a closed loop system.

Modified Facilities

Upon modification, new natural gas

- operated pneumatic controllers shall be low or no

- bleed

controllers or the controller discharge streams shall be routed into a closed loop system.

Within 60

- days of modif ication, e xisting natural gas

- operated pneumatic controllers shall be

replaced by or converted to low or no

- bleed controllers or the discharge streams of existing

natural gas

- operated pneumatic controllers shall be routed in to closed loop system.



## Well Completions

Operators shall submit applications to perform well completions using Best Management Practices. One

permit will be issued to each company that drills and completes wells within the Concentrated

Development Areas. The permits will be modeled after those issued to compa nies completing wells in

the Jonah and Pinedale Anticline Development Area. An example of a well completions or “Green

Completions” permit is available on the AQD website

, http://deq.state.wy.us/aqd or a copy may be

obtain ed by contacting the Wyoming Air Quality Division at (307) 777

- 7391 or (307) 473

- 3475

.

Green Completion permit applications shall be filed with the Division by November 1, 2010. * low b leed devices vent less than 6 cfhC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 16 of 7 1



## Presumptive BACT Requirements fo r CDA Facilities cont’d



## Produced Water Tanks

New Facilities

PAD Facilities

Upon FDOP

, VOC and HAP emissions from all active produced water tanks shall be

controlled by at least 98%

.

Single Well Facilities

Within 60

- days of FDOP , at sites where flashing emissions must be controlled by at least

98%, VOC and HAP emissions from all active produced water tanks shall be controlled by

at least 98%.

Modified Facilities

PAD Facilities

Upon m odification, VOC and HAP emissions from all new active produced water tanks

shall be controlled by at least 98%.

Wit hin 60

- days of m odification, existing open

- top, active, produced water tanks shall be

taken out of service for use as active produced water tanks. All active produced water

tanks shall be closed top and shall have VOC and HAP emissions controlled by at le ast

98%.

New and Modified Facilities

Open

- top or blow down tanks shall not be used as active produced water tanks but may

be used for blow down or for temporary storage during emergency or upset conditions,

such as spare tanks at facilities connected to liquids gathering systems, and do not have

to be tied into 98% control systems.

Removal of produced water tank emissions control may be allowed upon approval

. (see

Flashing , Page 11 )C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 17 of 7 1



## Presumptive BACT Requirements for CDA Facilities cont’d



## Blow down/Venting

Best Management Practices (BMP) and information gathering requirements will be incorporated into

permits for new and modified facilities.

BMP: During manual and automated blow down/venting episodes associated with liq uids

unloading, wellbore depressurization in preparation for maintenance or repair, hydrate clearing,

emergency operations, equipment depressurization, etc.

, associated VOC and HAP emissions

shall be minimized to the extent practicable. During manual blow down or venting, personnel

shall remain on site to ensure minimal gas venting occurs.

Information Gathering: Specific recordkeeping and reporting requirements will be established

during the permitting process and will include estimates of associated reg ulated air pollutants,

reasons for episodes, durations of episodes, steps taken to minimize emissions and descriptions

of emission estimation methods.

For companies with existing facilities as of the date of this Guidance, blow down and venting

permit app lications shall be filed by November 1, 2010.



## Emission sources without Presumptive BACT requirements

For uncontrolled sources emitting greater than or equal to 8 TPY VOC or greater than or equal to 5 TPY

total HAP s that do not have P

- BACT requirements, a BACT analysis shall be filed with the permit

application for the associated facility.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 18 of 7 1



## Presumptive BACT Requirements for JPAD Facilities

Flashing

For the purpose of determining flashing emissions all vapor streams containing VOC or HAP components

from all storage tanks (e.g., oil, condensate

, produced water with oil or condensate carryover) and all

separation vessels (e.g., gun barrels, production and test separators, production and test treaters, water

knockouts, gas boots, flash separators, drip pots, etc.) at a facility which are or may be vented to the

atmosphere shall be considered.

New Facilities

Upon FDOP

, VOC and HAP flashing emissions shall be controlled by at least 98%

.

Modified Facilit ies

Upon modification

, all new and existing VOC and HAP flashing emissions shall be controlled by

at least 98%.

New and Modified Facilities

Condensate and oil tanks that are on site for use during emergency or upset conditions, such as

spare tanks at facilities connected to liquids gathering systems, are not subject to the 98%

control requirements.

The removal of f lashing emissions control devices may be allowed upon approval after one year

if VOC flashing emissions have declined to les s than , and are reasonably expected to remain

below 8 TPY

.



## Dehydration Units

New Facilities

Upon FDOP

, all VOC and HAP emissions from dehydration unit process vents shall be controlled

by at least 98%. No control removal will be allowed.

Modified Facilities

Upon modification

, all VOC and HAP emissions from new and existing dehydration unit process

vents shall be controlled by at least 98%. No control removal will be allowed.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 19 of 7 1



## Presumptive BACT Requirements for JPAD Facilities cont’d



## Pneumatic Heat Trace Pumps & Other Pneumatic Pumps

New Facilities

Upon FDOP

, VOC and HAP emissions associated with the discharge streams of all natural gas

operated pneumatic pumps shall be controlled by at least 98% or the pump discharge streams

shall be routed into a closed loop system ( e.g., sales line, collection line, fuel supply line).

Modified Facilities

Upon m odification

, VOC and HAP emissions associated with the discharge streams of all new

and existing natural gas

- operated pneumatic pumps sha ll be controlled by at least 98% o r the

pump discharge streams shall be routed into a closed loop system.

New and Modified Facilities

For pneumatic pump emissions controlled by a combustion unit used to control flash or

dehydration unit emissions which m ay be removed, the control method for pump emissions will

be evaluated upon request for approval to remove the combustion unit . ( s ee F lashing , Page 18 )



## Pneumatic Controllers

New Facilities

Upon FDOP, natural gas

- operated pneumatic controllers shall be low * or no

- bleed controllers or

the controller discharge streams shall be routed into a closed loop system.

Modified Facilities

Upon modification, new natural gas

- operated pneumatic controllers shall be low or no

- bleed

controllers or the controller discharge streams shall be routed into a closed loop system.

Within 60

- days of modification, e xisting natural gas

- operated pneumatic controllers shall be

replace d by or converted to low or no

- bleed controllers or the controller discharge streams shall

b e routed into a closed loop system.

* low bleed devices vent less than 6 cfhC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 20 of 7 1



## Presumptive BACT Requirements for JPAD Facilities cont’d



## Produced Water Tanks

New Facilities

Upon FDOP, VOC and HAP emissions from all active produced water tanks shall be controlled by

at least 98%.

Modified Facilities

Upon modification, VOC and HAP emissions from all new active produced water tanks shall be

controlled by at least 98%.

Within 60

- days of modification, existing open

- top, active, produced water tanks shall be taken

out of service for use as active produced water tanks. All active produced water tanks shall be

closed top and shall have VOC and HAP emissions controlled by at least 98%.

New and Modified Facilities

Open

- top o r blow down tanks shall not be used as active produced water tanks but may be used

for blow down or for temporary storage during emergency or upset conditions, such as spare

tanks at facilities connected to liquids gathering systems, and do not have to be tied into 98%

control systems.

Removal of water tank emissions control may be allowed upon approval. (see Flashing , Page 18 )



## Well Completions

Operators shall submit applications to perform well completions using Best Management Practices. One

permit will be issued to each company that drills and completes wells within the JPAD area. The permits

will be modeled after those issued to companies completing wells in the Jonah and Pinedale Anticline

Development Area. An example of a well completions or “ Green Completions” permit is available on the

AQD website, http://deq.state.wy.us/aqd or a copy may be obtained by contacting the Wyoming Air

Quality Division at (307) 777

- 7391 or (307) 473

- 3475

.

Green Completion permit applications shall be filed with the Division by November 1, 2010

.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 21 of 7 1



## Presumptive BACT Requirements for JPAD Facilities cont’d



## Blow down/Venting

Best Management Practices (BMP) and information gathering requirements will be incorporated into

permits for new and modifie d facilities.

BMP: During manual and automated blow down/venting episodes associated with liquids

unloading, wellbore depressurization in preparation for maintenance or repair, hydrate clearing,

emergency operations, equipment depressurization, etc., associated VOC and HAP emissions

shall be minimized to the extent practicable. During manual blow down or venting, personnel

shall remain on site to ensure minimal gas venting occurs.

Information Gathering: Specific recordkeeping and reporting requireme nts will be established

during the permitting process and will include estimates of associated regulated air pollutants,

reasons for episodes, durations of episodes, steps taken to minimize emissions and descriptions

of emission estimation methods.

For co mpanies with existing facilities as of the date of this Guidance, blow down and venting

permit applications shall be filed by November 1, 2010.



## Emission sources without Presumptive BACT requirements

For uncontrolled sources emitting greater than or equal to 8 TPY VOC or greater than or equal to 5 TPY

total HAP s that do not have P

- BACT requirements, a BACT analysis shall be filed with the permit

application for the associated facility.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 22 of 7 1



## Determining Presumptive BACT Flashing Emissio n s

Flashing losses occur when produced liquids (crude oil or condensate) are exposed to temperature

increases or pressure drops as they are transfe r red from production vessels to other vessels or to

atmospheric storage tanks. For purposes of this guidance, the term “ flash emissions ” refers to VOC and

HAP pollutants associated with entrained natural gas vapors released to the atmosphere from

hydrocarbon liquids in surface production equipment. This production equipment may inc lude gun

barrels, separators, treaters, produced water tanks, gas drips, freewater knockouts

, etc. In addition to

flash emissions, vessels containing hydrocarbon liquids also have emissions associated with working and

breathing (also called standing) loss es. These are vapors displaced from oil or condensate due to

evaporation and agitating.

Use the following steps to determine projected potential flashing and working/breathing losses:

STEP 1: 30

- days after the First Date of Production calculate the aver age daily condensate or oil

production

. Example: Well produced 600 BBL during the first 30

- days after the First Date of Production.

average daily condensate/oil production = 600 BBL ÷ 30 days = 20 BPD

STEP 2: Calculate the projected first year annualized average daily condensate/oil production rate by

multiplying the average 30

- day rate times 0.6. This effectively results in a first year,

annualized daily production rate which is 20% of the initial production rate. Additionally, this

effective ly accounts for an 80% decline in daily production by the end of the first year.

( described in more detail on page 40 )

Example:

projected first year, annualized average daily oil/condensate production = 20 × 0.6 = 12 BPD

If the expected decline rate is less than 80%, then the expecte d decline rate should be used.

Using an expected decline rate > 80% requires pre

- approval from the Division.

STEP 3: Use an approved flash emissions model or direct measurement of tank emissions to

determine projected firs t year VOC and HAP emissions associated with the projected first

year average daily production rate

.

Actual flash emissions are determined the same as projected potential emissions except that the actual

average daily condensate or oil production rate is used rather than a projected production rate.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 23 of 7 1



## Determining Presumptive BACT Flashing Em ission s cont’d

Several methods are available to calculate or measure flash emissions with some being more accurate

than others. Even through working/breathing/flashing losses are almost always mixed together and exit

from a common vent at the same time, some methods onl y calculate working and breathing losses and

some only calculate flashing losses. Some methods will calculate all three types of emissions

simultaneously. Each method has specific constraints. For whichever method used, all supporting data

used to calcu late the emissions, including identification of the calculation method, description of

sampling methods and copies of lab sampling analyses shall be provided with the emissions estimate

.

Method Emissions

Calculated Comments

1 Direct measurement working, breathing,

flash Sampling and lab analysis required. Results are relatively

accurate.

2 Process Simulator flash only i.e. PROMAX, HYSIM, HYSIS

Software is expensive but results are accurate when based

on site

- specific sampling and lab analysis

.

3 API E &P TANKS Software

V 2.0 working, breathing,

flash Requires site specific sampling. Not as accurate as more

expensive process simulators and no longer supported by

the software producer (American Petroleum Institute).

4 Laboratory

measurement of the

Gas

- Oil

- Ratio (GOR) from

a pressurized liquid

sample flash only This is a direct laboratory analysis of the flash vapors

emitted from a pressurized oil/condensate sample.

5 EPA TANKS 4.0.9d working, breathing

only Program distributed by the EPA through their website at

http://www.epa.gov/ttn/chief/efpac/efsoftware.html

Extended hydrocarbon liquids analyses used for model input shall be no older than three years.

Composite analyses may be used as input. These are averaged extended hydrocarbon compositions

based on samples from at least five nearby wells producing from the same formation and under similar

conditions (± 25° psig) as the well being permitted . Analyses used as the basis for the average shall be

no older than three years.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 24 of 7 1



## Determining Presumptive BACT Dehydration Unit Emissions

Dehydration units use glycol (TEG, DEG or EG) to absorb water from produced gas before it is introduced

into gas sales or collection lines. Upon contact with wet gas, “lean” glycol absorbs water and other

liquids. It is then considered “rich”. To remove impurities, or regenerate, the rich glycol is routed

through a glycol flash separator and/or a reboiler. During flash separation and reboiling, water and

hydrocarbon vapors containing VOC and HAP pollutants are released from the rich glycol. These are

then discharged to the atmosphere from the dehydration unit process vents

.

Use the following steps to determine projected potential dehydration unit emissions :

STEP 1 : Once a new well has produced for 30

- days after the First Date of Production, determine the

average daily gas production rate

. Example:

Well produced 100 MMCF during the first 30

- days after the First Date of Production

average daily gas production = 100 MMCF ÷ 30 days = 3.3 MMCFD

STEP 2 : Calculate the projected first year , annualized average daily gas production rate by

multiplying the initial average 30

- day rate times 0.6. This effectively results in a first year,

annualized daily production rate which is 20 % of the initial production rate. Additionally, this

effectively calculates an 80% decline in daily prod uction by the end of the first year.

( described in more detail on page 40 .)

Example:

projected first year, annualized average daily gas production = 3.3 × 0.6 = 2.0 MMCFD

STEP 3 : Use GRI

- GLYCalc V3.0 or higher or other method approved by the Divisio n with the projected

first year, annualized average daily production rate to determine potential , annualized

uncontrolled VOC and HAP emissions from the dehydration unit process vents

. Process

vents include reboiler still vents, glycol flash separators an d still vent condensers.

Model input:

1) An extended hydrocarbon analysis of wet gas sampled upstream of the reboiler contact tower.

Analyses used for model input shall be no older than three years. Composite analyses may be used

as input. These are a veraged extended hydrocarbon compositions based on samples of wet gas

from at least five nearby wells producing from the same formation and under similar conditions (±

25° psig) as the well being permitted. Analyses used as the basis for the average shall be no older

than three years.

2) The projected first year average daily gas production rate (MMCFD).

3) Average, actual equipment operational parameters, including wet gas temperature and pressure,

dry gas water content, glycol flash separator tem perature and pressure, stripping gas source and

rate and average operating parameters of emission control equipment.

4) T he maximum lean glycol circulation rate (gpm) for the glycol ci rculation pump in use. Maximum

circulation rates for the most common ly used Kimray Model pumps are listed in TABLE 1

.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 25 of 7 1



## Determining Presumptive BACT Dehydration Unit Emissions cont’d



## TABLE 1

KIMRAY GLYCOL PUMP RATES

Model # Capacity (gpm) Working Pressure

(psi)

min max min max

3154 PV 0.05 0.22 100 1500

1715 PV 0.13 0.67 300 1500

4015 PV 0.2 0.67 300 1500

9015 PV 0.45 1.5 300 1500

21015 PV 1.1 3.5 400 1500

45015 PV 2.77 7.5 400 1500

4015 LP 0.13 0.33 100 500

2015 SC 0.13 0.33 100 500

5015 SC 0.2 0.83 100 500

10015 SC 0.37 1.67 100 500

20015 SC 1 3.33 100 500

D ata from Kimray O&G Equipment and Controls Catalog

Actual dehydration unit emissions are determined the same as projected potential emissions except

that the actual average daily gas production rate is used in the GlyCalc model rather than a projected

production rate.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 26 of 7 1



## BACT for Flashing Emissions

The following control systems or devices are accepted by the Div ision as meeting BACT for flash

emissions:

1) A vapor recovery device that is designed and operated and may be demonstrated to reduce the

mass content of VOC and total HAP emissions in the vapors vented to the device by at least 98% by

weight.

2) An enclosed, smokeless combustion device or flare that is designed and operated and may be

demonstrated to reduce the ma ss content of VOC and total HAP emissions in the vapors vented to

the device by at least 98% by weight.

3) Any other control device or configuration that can be demonstrated to reduce the mass content of

total HAP and VOC in the process gases vented to the device or configuration by at least 98% by

weight.

4) M onitoring and recordkeeping which will demonstrate continuous and effective emission control

are required upon start up of the control system. For a combustion device this may be a

thermocouple and c ontinuous recording device or any other equivalent device to detect and record

the presence of the pilot flame, or a combustion chamber temperature recorder/monitor. The

monitoring/recording requirements become enforceable permit conditions

. 5) Emissions control equipment, systems or devices, all vent lines, connections, fitting, valves, relief

valves, thief hatches or any other appurtenance employed to contain and collect vapors and

transport them to the emission control system or device, shall be maintained and operated during

any time a well is producing such that the emissions are controlled at all times

.

CAUTION : Total emissions from any facility or source shall not exceed major source levels prior to

emission control installation. Major s ource levels are 10 TPY of any single HAP, 25 TPY of any

combination of HAP or 100 TPY of any regulated pollutant. Flash emissions prior to control installation

will be determined using approved emission models or methods based on actual reported producti on

and operating conditions. Reported production includes that sold during well completion activities

which are reported to the WOGCC. Flash emissions are directly proportional to production rates,

provided operational parameters remain consistent, so it is acceptable to prorate emissions based on

production

.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 27 of 7 1



## BACT for Dehydration Unit Emissions

Other emission control systems or devices than those previously discussed may be used upon approval

by t he Division to meet BACT requirements for e missions from dehydration unit process vents (reboiler

still vents and vents from glycol flash separators or glycol flash tanks) . In order to be approved

, the

operator must provide a demonstration certifying the system or device will reduce the mass content of

total HAP and VOC in the process gases vented to the device or configuration by at least 98% by weight.

Emissions control equipment, systems or devices, all vent lines, connections, fitting, valves, relief valves,

hatches or an y other appurtenance employed to contain and collect vapors and transport them to the

emission control system or device, shall be maintained and operated during any time a well is producing

such that the emissions are controlled at all times.

M onitoring and recordkeeping which will demonstrate continuous and effective emission control are

required upon start up of the control system. For combustion devices this may be a thermocouple and

continuous recording device for the pilot flame or any other equival ent device to detect and record the

presence of the pilot flame. A temperature recorder/monitor might be used to demonstrate sufficient

heat of combustion or a continuous, wind

- up chart recorder might be used to demonstrate continual

operation by measurin g and recording temperature or pressure parameters.

R EMINDER : Dehydration units at oil and gas production facilities may be subject to additional NESHAP

requirements under 40 CFR part 63, subpart HH. It is the operator’s responsibility to comply with al l

applicable requirements of the NESHAP regulations.

CAUTION : Total emissions from any facility or source shall not exceed major source levels prior to

emission control installation. Major source levels are 10 TPY of any single HAP, 25 TPY of any

combination of HAP or 100 TPY of any regulated pollutant. Dehydration unit emissions occurring prior

to the installation of required controls will be determined using the GRI

- GLYCalc model or other method

approved by the Division based on the maximum lean glycol circulation rate and the actual reported gas

production rate including any gas which was routed through the dehydration unit during well

completion operations.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 28 of 7 1



## BACT for Sources without P

- BACT Requirements

For emission sources without PRESUMPTIVE BACT requirements, BACT shall be addres sed when the

uncontrolled source emits greater than or equal to 8 TPY VOC or greater than or equal to 5 TPY total

HAP emissions

.

For these sources EITHER the emission source will be controlled using BACT OR a BACT cost analysis will

be performed and submitted with the application showing either:

control is not technically feasible (i.e., due to physical constraints the emissions cannot be

controlled)

OR

control is not economically reasonable (i.e., based on a control cost analysis the “cost to control

per ton of pollutant reduced” is uneconomical).

CAUTION: BACT may be required at lower levels and for other emissions and emission sources

than those stated in this guidance, but as a minimum, BACT shall be considered when

equal to or above these guidance emission levels. For example, operators installing

pumping unit engines according the APP=NOI process might be asked to submit a BACT

analysis for the engine.

Multiple pieces of the same type of equipment are considered one emission source for permitting

purposes. For example, there are five oily rag burners at a facility . Uncontrolled e missions from the five

burners shall be aggregated for permitting purposes. If total uncontrolled VOC emissions from the five

burners are less than 8 TPY, BACT requirements are met wit h no control. If total uncontrolled emissions

from the five burners are greater than or equal to 8 TPY VOC or greater than or equal to 5 TPY total HAP,

emissions from all five burners shall be reduced to less than 8 TPY total VOC and less than 5 TPY tota l

HAP in order to meet BACT requirements or the applicant shall demonstrate controlling the emissions is

not economically reasonable n or technically feasible.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 29 of 7 1



## Permit Applications

For JPAD facilities, the application submittal process is different from the process for CDA and Statewide

facilities. See Page 3 8 for JPAD application instructions.

For CDA and Statewide facilities, u nless a permit is issued prior to start up, a C6 S2 Oil & Gas Production

Facilities permit application shall be filed within 90

- days after the First Date of Production for a new

facility or Date of Modification of an existing facility. The application notifies the AQD that the new or

modified facility has begun operation. It describes the facility process, equipment and associated

emissions/emissions controls and serves as a form of certification by the owner that the Presumptive

BACT r equirements have been met.

Whether the application is being filed after construction under the Presumptive BACT process or prior to

construction, the appropriate application forms depend upon the facility equipment and operating

scenario. A complete application includes the followi ng appropriate forms:

A cover letter stating the purpose of the application

A written process description and process diagram for the facility including each air emission

source and the operational parameters of each source ( examples on pages 31 & 32 )

Th e appropriate application forms

AQD

- OG0 Identification of application type ( application or NOI = application )

AQD

- OG00 Completeness checklist

AQD

- OG1 Application Cover Sheet

AQD

- OG2 Equipment List

AQD

- OG3 Storage Tanks, Pressurized Vessels & Pneu matic Pumps

AQD

- OG4 Dehydration Units

AQD

- OG5 Pumping Unit Engines

AQD

- OG6 Emission Summary

AQD

- OG7 Notice of Installation

AQD

- OG8 Multiple Facilities

AQD

- OG10 BACT cost analysis

Explanations or demonstrations of all methods used to calculate or estimate emissions for each

emission source, including controlled and uncontrolled sources. Emission calculation methods

are described later.

All applicable and required attachments noted on the forms, including

I nput and output for emission models/soft ware/process simulations

Equipment manufacturer’s emissions information

Laboratory analyses used for emission models/so ftware/process simulations or calculations

including a description of sampling procedures and handling, sampling locations, sampling

location parameters (i.e., pressure and temperature at sampling p ort)

Any additional attachments or information necessary for complete review of the applicationC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 30 of 7 1



## Permit Applications cont’d

Download application forms from the AQD we bsite :



## http://deq.state.wy.us/aqd/oilgas.asp

Contact the Wyoming Air Quality Division at (307) 777

- 7391 or (307) 473

- 3475

Make written request to : Wyoming Department of Environmental Quality

Air Quality Division

Herschler Building, 2

- E

122 W est 25 th Street

Cheyenne, WY 82002

attn: O&G NSR Permitting

or

Wyoming Department of Environmental Quality

Air Quality Division

152 North Durbin Street, Suite 100

Casper, WY 82601

attn: O&G NSR Permitting

For facilities constructed or modified under the Presumptive BACT process submit EITHER 1 paper copy

with original signature and 1 electronic copy OR 3 paper copies (one with original signature) of the

complete C6 S2 application within 90

- days of the First Date of Production to the address below.

For all facilities where emissions are known prior to construction submit EITHER 1 paper copy with

original signature and 1 electronic copy OR 3 paper copies (one with original signature) of the complete

C6 S2 application prior to construction to the address below.

NSR Program Manager / attn: O&G Production Facilities

Department of Environmental Quality

Air Quality Division

Herschler Building, 2

- E

122 W est 25 th Street

Cheyenne, WY 82002

The preferred method for filing the application is 1 paper copy with 1 electronic copy.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 31 of 7 1



## Permit Applications cont’d

Example Process Diagram & Description

EXAMPLE: Air emission sources in the diagram are the condensate storage tank from which vapors are vented to the

atmosphere, the dehydration unit reboiler still vent and the three natural gas

- fired process heaters. P roduced fluids are

directed to the 3

- phase separator for separation of condensate/water/gas. Wet gas is directed to the TEG dehydration unit for

drying. Separated condensate and water are routed to the appropriate tanks for storage prior to being hauled from location via

truck. Produced gas is used as burner fuel. Reboiler vapors and flash emissions are vented to the atmosphere along with

S/W/B losses from the condensate tank. 500

- bbl

Produced

Water Tank

1000 BWPD 400

- bbl

Condensate

Tank

20 BPD 4.0 MMCFD

TEG

Dehydration

Unit 3

- Phase

Separator

500 psig

85 oF

Separated Condensate/ Water to

Storage Tanks Dry Gas to Sales 1.0 MMBtu/hr

Reboiler Heater Wet Gas to

Dehy

Well Fluids

to Separator Reboiler Vapors

to Atmosphere

Flash and S/W/B Vapors to

Atmosphere

0.50 MMBtu/hr

Tank Heater

Truck Loadout (20 BPD)C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 32 of 7 1



## Permit Applications cont’d

Example Process Diagram & Description

EXAMPLE: Total well fluids from four wells flow to the 2

- ph HP separators. Wet gas from the HP separators flows to the four

dehydration units. Separated fluids from the 2

- ph HP separators flows to the 3

- ph LP separators. Se parated condensate and

water flows from the 3

- ph LP separators to the storage tanks. Gas released in the 3

- ph separators is routed to the condensate

storage tanks. Tank vapors, including tank flash, gas from the 3

- ph LP separators and S/W/B vapors are co llected and directed

to a 30

- foot smokeless combustor. The temperature of the combustor is continually monitored and recorded using a SCADA

system. Reboiler still vents vapors flow through condensers. Condensed liquids are pumped to the condensate stora ge tanks.

Non

- condensable vapors flow to the 20

- foot Mini

- Combustors. The temperature of the Mini

- combustors is continually

monitored and recorded using a SCADA system. Pneumatic heat trace pumps operate 6 months per year using produced gas

from the HP separators to operate. Vent lines from the pumps are routed into the condensate dump lines from the LP

separators.

The process diagram does not need to be computer generated. A simple hand sketch is sufficient as

long as the required information is inc luded. The diagram does not need to be drawn to scale and does

not need to represent the exact position of production equipment at the facility as long as the process

description and operating scenario are clearly defined. Well 1 HP 2

- Phase Separators with 0.5

MMBtu/hr heaters

600 psig, 80 deg F

400

- bbl

Condensate Tank 400

- bbl

Condensate Tank

Combustor Tank Flash, LP Separator Flash, S/W/B losses

Mini

Combustor

4.0 MMCFD

TEG

Dehydration

Unit with 0.085

MMBtu/hr

reboiler 6.0 MMCFD

TEG

Dehydration

Unit with 0.75

MMBtu/hr

reboiler Mini

Combustor Separated Condensate

& LP Separator Flash

Pn eumatic Heat Trace Pumps Condenser

20 psig, 130 deg F

LP 3

- Phase Separators

60 psig, 120 deg F

Separated

Water

Truck Loading

Well 2 Well 3 Well 4

Separated Wet Gas

Dry gas to Sales

Pipeline

400

- bbl Water Tank 400

- bbl Water Tank Separated Liquids

Condenser

20 psig, 130 deg F 6.0 MMCFD

TEG

Dehydration

Unit with 0.5

MMBtu/hr

reboiler 10.0 MMCFD

TEG

Dehydration

Unit with 0.75

MMBtu/hr

reboilerC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 33 of 7 1



## Permit Applications cont’d

Upon receiving the application, the AQD sends a receipt letter to the applicant. The application is

logged into the AQD tracking system and assigned a reviewing engineer. The engineer has up to 30

- days

to perform a completeness review to ensure adequate and correct information has been filed. If the

application is deemed incomplete the engineer will notify the applicant and request further information.

Upon completeness the engineer has 60

- days to complete a technical review, write an application

analys is and make any recommendations. During this process the decision to issue a permit or waiver

takes place. If the decision is to issue a permit, the proposed permit, including compliance

requirements, is published for a mandatory 30

- day public comment pe riod. If no comments are

received the permit is issued once the public comment period ends. If comments are received these are

addressed by the AQD. It is possible comments will warrant a public hearing. When this is the case, a

final permit may be den ied or delayed.

An hourly fee will be assessed for the time it takes AQD personnel to process the application. A bill will

be sent to the applicant when the process is complete. Billing is handled as follows:

Initial billing is assessed when a propose d permit is sent to public notice. Initial billing shall be

paid prior to issuance of the final permit.

Final billing is assessed for waivers and permits after these are issued.

Contact the Division for the current hourly rate.

NOTE: The Presumptive BACT permitting process may not be used for sour gas (H

2 S) production facilities

unless the only emissions of H

2 S will be those associated with fugitive losses from valves, fittings , surface

piping and pneumatic devices, etc. I f there will be H 2 S emissions associated with vented gas or tank

vapors or if sour gas will be flared the applicant shall contact the Division for permitting guidance prior

to construction

.

NOTE: NO internal combustion compressor engines or generator engines may be installe d under the

Presumptive BACT process. No pumping unit engines greater than 50

- Hp or with nitrogen oxide (NO

X )

emissions greater than 5 TPY may be installed under the Presumptive BACT permitting process.

Such engines shall be permitt ed prior to installa tion.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 34 of 7 1



## Permit Applications cont’d



## NOTICE of INSTALLATION (NOI)

For some O&G production facilities or equipment, associated air emissions are considered relatively

insignificant by the AQD. In these cases the NOI form, FORM AQD

- OG7 , serves as a complete C6 S2

permit application.

The NOI can be used for f acilities such as single wellsites, consisting of only a wellhead or perhaps a

separation unit

, where no produced fluids are stored or dehydrated. Instead

, the produced fluids ar e

routed directly from the wellhead or separation vessels into a sales line, collection system or to a

separate facility for treatment, storage and sales. T he only emissions at this type of facility would be

fugitive emissions from equipment leaks and fit ting s , or NO X and CO emissions associated with small

natural gas fired process heater s

.

The NOI may be used as a complete permit application ONLY if ALL of the following apply to the facility

owner :

T here are no hydrocarbon liquids storage tanks.

There are no dehydration unit s

.

T here are no pressurized vessels from which hydrocarbon vapors are vented to the atmosphere

ot her than during upset or emergency conditions.

There are no internal combustion pumping unit engine s ≥ 50 HP or with ≥ 5 TPY NO X emissio ns.

There are no H 2 S emissions from the facility other than those associated with fugitive leaks from

process components and surface piping.

There are no SO

2 emissions associated with the combustion of sour gas

.

REMINDER for Pumping Unit Engines : Pumping unit engines at oil and gas production facilities are

subject to additional NESHAP requirements under 40 CFR part 63, subpart ZZZZ. Also, engines at these

facilities may be subject to additional NSPS requirements under 40 CFR part 60, subpart JJJJ based on

engine manufacture date. It is the operator’s responsibility to comply with all applicable requirements

of the NSPS and NESHAP regulations.

Using the NOI as notification of equipment replacement s and changes

The NOI may be used for notification of eq uipment change outs or replacements

, provided the changes

will not significantly increase permitted emissions, if at all. For example, use the NOI as notifi cation of

replacement of a TEG dehydration unit with one having a higher design rating but with the same model

glycol pump as previously permitted, o r higher rated reboiler burner

. Increased emissions associated

with the larger burner wo uld be considered insignificant and there would be no emiss ions increase

associated with the larger dehy as long as there is no change in the glycol pump model or wet gas

throughput

.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 35 of 7 1



## Permit Applications cont’d



## NOTICE of INSTALLATION (NOI)

Another example would be to use t he NOI as notification of the installation of additional production

tanks at a previously permitted facility provided throughput to the current and additional tanks is the

same as or less than the previously permitted throughput and provided the vent lines of the new tanks

are tied into emission control devices if such was requi red for the existing tanks

. The NOI may be used as notification of the installation of different process heater, such as replacing a

0.5 MMBtu/hr line heater with a 0.75 MMBtu/hr line heater.

Examples are illustrated on the next page

.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 36 of 7 1



## Permit Applications cont’d



### Examples of cases where the NOI may be used as a complete C6 S2

permit application or as notification of equipment changes

flowing well

separator produced fluids to gathering

system or separate facility gas to sales or collection

system process heater

electric

pumping unit produced oil to gathering system

or separate facility

produced water 

## 1

2

3

<50 Hp & < 5 TPY NOx

pumping unit with natural

gas

- fired engine SOUR fluids to treater heater

treater s our production to gather ing

system or separate facility



## 4 A storage tank is added to an

existing facility. Tank

throughput at the facility is no

greater than previously

p ermitted throughput. If

existing tanks are connected

to an emission control device,

the new tank shall also be

connected to the control

device. install new tank SWEET gas burner fuelC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 37 of 7 1



## Permit Applications cont’d



## Notice of Installation (NOI)

How to obtain NOI Form AQD

- OG7

The link to electronic forms on the AQD website is



## http://deq.state.wy.us/aqd/oilgas.asp

Contact the Wyoming Air Quality Division at 

## (307) 777

- 7391 or (307) 473

- 3475

Make written request to: Wyoming Department of Environmental Quality

Air Quality Division

Herschler Building, 2

- E

122 W est 25 th Street

Cheyenne, WY 82002

When/where to file a NOI

Within 60

- days of the First Date of Production , equipment change out, equipment replacement or

equipment addition submit EITHER 1 paper copy with original signature and 1 electronic copy OR 3

paper copies (one with original signature) of the NOI form to:

NSR Program Manager / attn: O&G Production Facilities

Department of Environmental Quality

Air Quality Division

Herschler Building, 2

- E

122 West 25 th Street

Cheyenne, WY 82002

The preferred method for filing t he NOI is 1 paper copy with 1 electronic copy.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 38 of 7 1



## Specific Requirements for JPAD Permit Applications

For JPAD , the Presumptive BACT permitting process varies from that for all other statewide areas.

Unlike the Presumptive BACT permitting process for CDA and S tatewide facilities, the permitting

process for JPAD facilities does not require the determination of projected, potential emissions prior to

application filing. Instead, emissions meeting the BA CT requirements shall be in place upon the First

Date of Production at all new and modified facilities. A C6 S2 application is filed to notify the AQD of the

start up of a new facility or the modification to an existing facility

. The application describe s new

, modified and future well/ equipment installations along with the associated, controlled and uncontrolled

emissions and serves as a form of certification by the owner that Presumptive BACT requirements for

emission control s and control device monitoring have been and will be met.

A c omplete C6 S2 a pplication , including all appropriate forms, shall be filed for within sixty

- days of the

First Date of Production or modification for :

all n ew single well facilities

all new PA D facilities

modifications to existing single or PAD facilities

If a facility has been previously permitted and the permit contains co nditions authorizing additional

equipment and wells to be added according to the July 28, 2004 Guidance Addendum, a comp lete

application ma y be submitted using the AQD Pinedale

- 1 Form

.

Any additional attachments or information necessary for complete review of the application

Emissions reported in the application shall be based on projected rates for new wells and current

average production rates at the time of application filing for existing wells. Higher production rates may

be used if the applicant wants to permit for production/emission increases.

NOTE: At facilities with a permit authorizing the addition of future wells, the authorization becomes

invalid if no wells are added to the facility within 24 months after receipt of the permit or if the addition

of the planned wells is discontinued for a period of 24 months or more. The permit for the existing wells

remain s valid.

For facilities requiring a permit prior to start up of operations, emissions reported in the application

should be based on expected production rates. Higher production rates may be used if the applicant

wants to permit for production/emissions increases.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 39 of 7 1



## Specific Requirements for JPAD Permit Applications cont’d

How to obtain C6 S2 application, AQD Pinedale

- 1 and NOI forms

Download electronic forms from the AQD website at:



## http://deq.state.wy.us/aqd/oilgas.asp

Contact the Wyoming Air Quality Division at 

## (307) 777

- 7391 or (307) 473

- 3475

Make written request to:

Wyoming Department of Environmental Quality

Air Quality Division

Herschler Building, 2

- E

122 W est 25 th Street

Cheyenne, WY 82002

attn: O&G NSR Permitting

When/where to file C6 S2 permit applications

, AQD Pinedale

- 1 and NOI forms

For facilities where emissions are known prior to construction submit EITHER 1 paper copy with original

signature and 1 electronic copy OR 3 paper copies (one with original signature) of the complete C6 S2

application PRIOR to construction to the address below.

For facilities constructed or modified under the Presumptive BACT process submit EITHER 1 paper copy

with original signature and 1 electronic copy OR 3 paper copies (one with original signature) of the

complete C6 S2 application within 60

- days of the First Date of Production to the address below.

For facilities with additions authorized under the July 28, 20 04 Guidance Addendum, use the AQD

Pinedale

- 1 Form

. S ubmit EITHER one electronic and one paper copy with original signature OR three

paper copies (one with original signature) within 60

- days of the First Date of Production to:

NSR Program Manager / attn: O&G Production Facilities

Department of Environmental Quality

Air Quality Division

Herschler Building, 2

- E

122 W est 25 th Street

Cheyenne, WY 82002

The preferred method for filing the application is 1 paper copy with 1 electronic copy.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 40 of 7 1



## The 0.6 decline factor ....

The first year daily production rates are represented by the jagged line BOX 1 . The area under the line

represents the total actual production volume for the first year . It is difficult to calculate the total

volume under the jagged li ne so it is smoothed out BOX 2 using statistical methods.

BOX 1 BOX 2

BOX 3 BOX 4

The smoothed curve is “straightened” out in BOX 3 , then “leveled” out in BOX 4 . Now the total production for the

first year is represented by the area under the line in BOX 4 which is easily calculated. Production curves from a

large sampling of Wyoming wells indicate the average well declines by 80% during the first year. That 80% decline

is represented by the level line in BOX 4 after the first 30

- day average production rate is multiplied by 0.6. For the

first month the well makes an average 3.333 MMCF D. With 80% decline during the first year, the well will make

0.667 MMCFD at the end of the first year (3.333

- 0.8(3.333) = 0.667). Then the average daily production rate over

365 days is (3.333 + 0.667)/2 = 2.0 MMCFD which is the same as 3.333 × 0.6 = 2.0.

start up 365 days

MMCFD

start up 365 days

2.0 MMCFD start up 365 days

start up 365 days

MMCFD

The “smoothed” curve in BOX 2 is

“straightened” out using mathematical

methods. EXAMPLE

- actual daily gas production rate vs time

Actual production during the first year is represented by the area

under the jagged line which ultimately turns out to be ≈ 730

MMCF. The jagged line representing daily

production is “smoothed” out u sing

statistical methods.

“leveled” out, projected daily gas production rate vs time

Total projected production for the first year is represented

by the area under the straight line

2 MMCFD × 365 days = 730 MMCF

First year projected emissions are based on 730 MMCF of

produced gas.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 41 of 7 1



## B L A N KC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 42 of 7 1



# APPENDIX A

F O R M SC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 43 of 7 1



## B L A N KC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 44 of 7 1

Form AQD

- OG0 Application

Identifies the submittal as a C6 S2 O&G Production Facilities Permit ApplicationC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 45 of 7 1

Form AQD

- OG0 NOI

Identifies the submittal as a C6 S2 O&G Production Facilities Notice of Installation = ApplicationC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 46 of 7 1

Form AQD

- OG0 0 Completeness ChecklistC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 47 of 7 1

Form AQD

- OG 1 Application CoversheetC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 48 of 7 1

F orm AQD

- OG2 Equipment ListC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 49 of 7 1

Form AQD

- OG2 Equipment List

, Page 2C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 50 of 7 1

Form AQD

- OG3 Storage Tanks, Pressurized Vessels & Pneumatic PumpsC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 51 of 7 1

Form AQD

- OG4 Dehydration UnitsC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 52 of 7 1

Form AQD

- OG5 Pumping Unit EnginesC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 53 of 7 1

Form AQD

- OG6 Emission SummaryC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 54 of 7 1

Form AQD

- OG7 Notice of InstallationC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 55 of 7 1

Form AQD

- OG8 Multiple FacilitiesC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 56 of 7 1

Form AQD

- OG9 Change of OwnershipC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 57 of 7 1

Form AQD

- OG10 BACT Cost AnalysisC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 58 of 7 1



## B L A N KC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 59 of 7 1



# APPENDIX B

EMISSION CALCULATIONSC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 60 of 7 1



## B L A N KC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 61 of 7 1

Emissions from processes and equipment which shall be accounted for and reported by applicants FOR

ALL O&G PRODUCTION FACILITIES are:

Emission Unit or Process Associated Emissions

storage tanks (flashing & S/W/B losses) VOC HAP H 2 S

pressurized vessels (flashing losses) VOC HAP H 2 S

dehydration units (reboiler still vents & glycol flash tanks) VOC HAP

natural gas fired burners, heaters, flares NO X CO SO 2

natural gas operated pneumatic pumps VOC HAP H 2 S

fugitives VOC HAP H 2 S

natural gas fired engines NO X CO SO 2

truck load out VOC HAP H 2 S

AP

- 42 EMISSION FACTORS

Throughout this Guidance reference is made to AP

- 42 emission factors. The complete AP

- 42

compilation may be downloaded from http://www.epa.gov/ttn/chief/ap42/index.html

STORAGE TANK EMISSIONS

Flashing and Standing/Working/Breathing ( S/W/B ) losses are the terms for emissions which occur

when hydrocarbon liquids are exposed to temperature and pressure changes (i

. e

. , from separator

pressure and temperature to storage tank pressure and temperature) causing hydrocarbon vapors to be

released from the liquids. The vapors may contain VOCs, HAPs and H

2 S.

Software is available for modeling these emissions. Models accepted by the Air Quality Division are

those using Peng

- Robinson or S

- R

- K methods base d on widely accepted principals of behavior for

hydrocarbon vapors and liquids. Some common software programs for estimating these emissions are

PROMAX, HYSIM, HYSYS, K

- FLASH, PROSIM and API E&P TANKS v2.0. The models require input detailing

chemical pro perties of the fluids handled and physical operating parameters of the system(s) and

production equipment. Output from the models includes volumes, rates and chemical components of

the individual process streams from tanks and pressurized vessels.

Emiss ions from storage tanks may also be physically measured. In order to do so all tank valves,

hatches, relief devices, leaks, etc. shall be sealed. Tank vapors shall only be allowed to exit the tank

through a metered outlet. Usually this requires a meter capable of measuring low volumes. The

measurement period shall last long enough to capture a representative tank vapor volume. An

extended hydrocarbon analysis of the vapors shall be obtained along with the vapor volume.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 62 of 7 1

MEASURED TANK FLASH EMISSIONS

- EXAMPLE CALCULATION

The tons per year of VOC and HAP emissions associated with tank flashing are calculated as follows:

Given: Condensate tank vapors = 1000 scf/day

VOC weight % = 20

HAP weight % = 5

Conden sate vapor molecular weight = 20 lb/lb

- mol

TPY total flash emissions = 1000 scf/day × (1 lb

- mol/379 scf) × (20 lb/lb

- mol) × (ton/2000 lb) × (365 days/year) = 9.6 TPY

TPY total VOC emissions = 9.6 TPY × (20 weight % VOC / 100) = 1.9 TPY VOC

TPY total HAP emissions = 9.6 TPY × (5 weight % HAP / 100) = 0.5 TPY HAP

S/ W / B losses

Not all software programs include tools for estimating S/ W / B losses. There is free software available

from the EPA named EPA TANKS. The most recent available version of EPA TANKS is ver. 4.09D. The

software may be downloaded from the EPA website at

http://www.epa.gov/ttn/chief/software/tanks/index.html

PRESSURIZED VESSELS

Whenever vapors from a pressurized vessel (separator, treater, FWKO, flash separator, gunbarrel, gas

boot, etc) are released to the atmosphere, other than during times of emergency or upset conditions,

emissions associated with those vapors shall be accounted for.

The same flash emission models mentioned above, for tank flash emissions, are often used to estimate

emissions from pressurized vessels. Again, an extended hydrocarbon analysis of the liquids involved and

actual operational conditions of the production equipment are necessary as input for the models.

Even when vapors from a pressurized vessel are collected for use as process burner fuel or fuel for an IC

engine, for example, emissions associated with the total vapors shall be accounted for when considering

potential emissions from a facility. If the volume and rate of vented vapors are known and an extended

hydrocarbon analysis is available, associated emissions may be calculated in the same manner as

described on Page 68 (calculation of flash emissions). If these are not available, the volumes shall be

measured and analyzed in order to perform the calculations and determine associated emissions.

DEHYDRATION UNIT EMISSIONS

Air pollutants, mostly VOCs and HAPs, are associated vapors released from reboiler still vents and glycol

flash separators. To estimate these emissions the GRI

- GLYCalc v3.0 or higher model or other approved

method is used. This relatively inexpensive software was created by the Gas Research Institute (GRI) for

d etermining optimal operating parameters for dehydration units and is available from the Gas

Technology Institute (GTI) with a website address of http://www.gastechnology.org

Input for the model includes an exten ded hydrocarbon analysis of wet gas sampled upstream of the

contact tower, actual operating parameters of all associated equipment (i

. e

., reboiler still vent temp.,

flash separator temp., dry gas flow rate, glycol recirculation rate, condenser, etc) and ph ysical properties

of the dry and wet gas streams. The model provides an estimate of individual emission components and

the rates of vapor and liquid streams exiting each process vent of a dehydration unit. When submitting

a GRI

- GLYCalc model it is only n ecessary to submit the INPUT SUMMARY, EMISSIONS SUMMARY,

CONDENSER VENT OUTPUT (if applicable) and FLASH TANK OUTPUT (if applicable).C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 63 of 7 1

NATURAL GAS FIRED HEATERS (external combustion equipment)

NO X , CO and VOC emissions from process unit heaters should b e calculated using the emission factors

(EF) below from EPA AP

- 42, Tables 1.4

- 1, 1.4

- 2 and 1.5

- 1. The following lists these factors:

Emission Factors for Industrial and Commercial Boilers

Pollutant Butane Gas 1 Propane Gas 2 Natural Gas 3 Natural Gas 3

(0.3 to 100 MMBtu/hr heat input) (0.3 to 100 MMBtu/hr heat input) <100 MMBtu/hr heat input

NO X 4 15 lb/1000 gal 13 lb/1000 gal 0.098 lb/MMBtu 100 lb/MMcf

CO 4 8.4 lb/1000 gal 7.5 lb/1000 gal 0.082 lb/MMBtu 84 lb/MMcf

TOC 4,5 1.1 lb/1000 gal 1.0 lb/1000 gal 0.010 lb/MMBtu 11 lb/MMcf

1 Based on an average heating value of 102 × 10 6 Btu/1000 gallons of Butane.

2 Based on an average heating value of 91.5 × 10 6 Btu/1000 gallons of Propane.

3 Based on an average heating value of 1020 Btu/SCF of natural gas.

4 The emission factors in this table may be converted to other natural gas heating values by multiplying the given emission

factors by the ratio of the heating value of the actual gas used to the average heating values listed

Converted EF = (EF from table a bove × (actual heat value/heat value in table)).

5 VOC emissions may be determined by multiplying the calculated TOC (total organic compounds) emission rate by the weight

percent of VOC compounds in the actual fuel gas stream.

HEATER EMISSIONS

- EXAMPLE C ALCULATION

Given: Separator heater rating = 0.5 MMBtu/hr

Gas Heating Value = 1300 Btu/scf

VOC weight % = 20

Annual operating hours = 8760

NO X EF = 100 lb/MMcf

CO EF = 84 lb/MMcf

TOC EF = 11 lb/MMcf

NO X emissions = (0.5 MMBtu/hr) × (100 lb/MMcf) × (1300 Btu/1020 Btu) x (1 scf/1020 Btu) × (8760 hr/yr) × (ton/2000 lb) = 0.27 TPY NO X

For CO emissions, the same calculation is used except the EF is 84 lb/MMcf.

VOC emissi ons = 0.5 × 11 x (1300/1020) x 1/1020 × 8760/2000 x (20% VOC/100) = 0.006 VOC TPY VOC ← INSIGNIFICANT at less than 0.1 TPY

FLARES

The NO

X and CO emissions for flares should be based on 0.14 lb NO

X /MMBtu and 0.035 lb CO/MMBtu

and the reported fuel usage based heat input. VOC and HAP emissions from flaring should be based

upon the guaranteed destruction efficiency of the flare. Reported flared gases shall include pilot gas

with heat content and flared gas with average estimat ed heat content. The rational for using these

factors as opposed to AP

- 42 factors for flares is that the flare factors are believed to be only applicable

to chemical plant type flares engaged in burning low BTU gases. The gases typically burned in flares in

Wyoming contain more than 900 Btu/scf and emissions are expected to be closer to the AP

- 42 factors

for NO

X and CO from gas fired heaters and boilers greater than 10 MMBtu/hr.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 64 of 7 1

FLARE EMISSIONS

- EXAMPLE CALCULATIONS

– CONDENSATE TANK FLASH

Given: Total waste gas = 125 scf/hr

Gas heating value = 1350 Btu/scf

H 2 S weight % = 5.5

H 2 S mole % = 4.4

Tank vapor MW = 28 lb/lbmol

SO 2 MW = 64 lb/lbmol

NO X emissions = (125 scf/hr) × (1350 Btu/scf) × (0.14 lb NO

X /MMBtu) × (MMBtu/10 6 Btu) × (8760 hr/yr) × (1 ton/2000 lb) = 0.1 TPY NO

X

Unflared H 2 S emissions = (125 scf/hr) × (28 lb/lb

- mol) × (1 lb

- mol/379 scf) × (8760 hr/yr) × (ton/2000 lb) x (5.5/100) = 2.2 TPY H

2 S

Flared H 2 S emissions = (2.2 TPY) × (100%

- 98%/100)= 0.04 TPY H

2 S ← INSIGNIFICANT at less than 0.1 TPY

SO 2 emissions from flaring sour gas = (125 scf/hr) × (8760 hr/yr) × (1 lb

- mol/379 scf) × (64 lb SO

2 /lb/mol) × (ton/2000 lb) × (4.4/100)

= 4.1 TPY SO 2

FLARE PILOT EMISSIONS

Given: Flare pilot gas = 5 scf/min

Gas heating value = 1000 Btu/scf

NO X emissions = (5 scf/min) × (1000 Btu/scf) × (0.14 lb NO

X /MMBtu) × (MMBtu/10 6 Btu) × (60 min/hr) × (8760 hr/yr) × (1 ton/2000 lb)

= 0.18 TPY NO X

For CO emissions the same calculations are used except the EF for CO is 0.035 lb/MMBtu.

FLARE EMISSIONS EXAMPLE CALCULATION

– DEHYDRATION UNITS

Given: Glycol flash separator vapors = 25 scf/min

Reboiler still vent vapors = 5 scf/min

Total waste gas = 30 scf/min (25 scf/min glycol flash vapors + 5 scf/min reboiler still vent vapors)

Gas Heating Value = 1050 Btu/scf ( assume at least 1000 BTU/SCF if the heat content is unknown )

NO X emissions = (30 scf/min) × (1050 Btu/scf) × (0.14 lb NO

X /MMBtu) × (1 MMBtu/10 6 Btu) × (60 min/hr) × (8760 hr/yr) × (1 ton/2000 lb)

= 1.1 TPY NO X

For CO emissions the same calculations are used except the EF for CO is 0.035 lb/MMBtu.

PNEUMATIC PUMPS

If a pneumatic pump uses natural gas as the motive gas, the pump will release VOC and HAP emissions

each time it strokes since all motive gas is vented by the pump. To determine emissio ns from the pump,

manufacturer’s information regarding gas usage shall be known as well as the hydrocarbon composition

of the motive gas.

PNEUMATIC PUMP EMISSIONS

- EXAMPLE CALCULATION

A Texsteam Series MX pump is used to circulate hot glycol in heat trace lines. The pump moves 0.15

gallons per 40 strokes and is currently stroking at 20 strokes per minute (spm). The pump requires 24

scf for each gallon of glycol pumped. The pump motive gas weighs 20 lb/lb

- mol and contains 50 wt%

VOCs and 30 wt% HAPs

. Pump usage/vent rate = (20 strokes/min) × (0.15 gallons/40 strokes) × (24 scf/gallon) = 1.8 scf/min

VOC emissions = (1.8 scf/min) × (20 lb/lb

- mol) × (lb

- mol/379 scf) × (ton/2000 lb) × (525600 min/yr) × (50 wt% VOC/100) = 12.5 TPY VOCC6 S2 O&G Production Facilities Permitting Guidance

March 2010

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TRUCK LOADING

VOC emissions from loading oil or condensate into tank trucks should be estimated using the following

formula with data from AP

- 42 tables.

L L - 12.46 × S × P × M/T

Where: L L = loading loss, pound per 1,000 gallons of liquid loaded (lb/1000 gal)

S = a s aturation factor (See Table 5.2

- 1 below)

P = true vapor pressure of liquid loaded (psia)

M = molecular weight of tank vapors (lb/lb

- mol)

T = temperature of bulk liquid loaded (oR) (oR = oF + 460)

" S " values are obtained from Table 5.2

- 1.

" M " and " N " val ues are obtained from Table 7.1

- 2.

T able 5.2

- 1 Saturation (S) Factors for Calculating Petroleum Liquid Loading Losses

Cargo Carrier Mode of Operation " S " Factor

tank trucks and rail tank cars submerged loading of a clean cargo tank 0.50

submerged loading: dedicated normal service 0.60

submerged loading: dedicated vapor balance service 1.00

splash loading of a clean cargo tank 1.45

splash loading: dedicated normal service 1.45

splash loading: dedicated vapor balance service 1.00

Table 7.1

- 2 Properties of Selected Petroleum Liquids

Only crude oil properties are supplied here. The full table of values can be found in AP

- 42, Table 7.1

- 2)

petroleum

liquid vapor

molecular

weight at 60oF

(lb/lb

- mol) condensed

vapor

density at

60oF (lb/gal) liquid density at 60oF

(lb/gal) true vapor pressure (psi) at various temperatures in

oF

40 50 60 70 80 90 100

" M " " P "

Crude Oil

RVP 5 50 4.5 7.1 1.8 2.3 2.8 3.4 4.0 4.8 5.7

TRUCK LOADOUT

- EXAMPLE CALCULATION

Given: Condensate loaded = 360 bbl crude/month

S = 0.6

P = 2.3 psi

M = 50 lb/lb

- mol

T = 50

L L = (12.46) × (0.60) × (2.3 psi) × (50 lb/lb

- mol) = 1.69 lb/1000 gal

(50oF + 460)

Loading losses (TPY) = (1.69 lb/1000 gal) × (annual sales of 360 bbl/mo) × (12 mo/yr) × (42 gal/bbl) × (ton/2000 lb) = 0.15 TPYC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 66 of 7 1

FUGITIVE EMISSIONS

The easiest way to calculate total hydrocarbon fugitive emissions is to multiply the number of

components at a site by the EPA Average Emissions Factors sho wn in the tables below. The first table

lists the average emission rates of total hydrocarbon (THC) to be assumed for all components in

hydrocarbon service installed at a site. The factors are current as of June 15, 1996 and given in pounds

per component

- day (lb/component

- day). The second table lists speciated rates.

The only information needed for this method is a count or estimate of the number of flanges,

connectors (other than flanges), open

- ended lines, pumps, valves and "other" components at the site

grouped by stream (gas, light oil, heavy oil, water/oil). The number of components can be determined

by either counting them in the field or by estimating them.

EPA Average Emission Factors for Total Hydrocarbon (THC) Emissions

From O&G Production O perations

(lb/component

- day)

equipment type equipment service category

gas heavy oil

(< 20oAPI) light oil

(> 20oAPI) water/light oil 1

connector .011 .0004 .011 .0058

flange .021 .000021 .0058 .00015

open ended line .11 .0074 .074 .013

other 2 .47 .0017 .4 .74

pump .13 not available .69 .0013

valve .24 .00044 .13 .0052

SOURCE: US EPA Bulletin Board (Leaks_OG.WP5; 8/9/1995)

1 The water/light oil emission factors apply to water streams in light oil service with water content between 50% and 99%. For streams with

water content > 99% the emission rate is considered negligible.

2 The “other” equipment type includes compressor, pressure relief valves, diaphragms, drains, dump arms, hatches, instruments, meters,

polished rods and vents.

NOTE: The emission factors in the table above are not intended to be used to represent emissions from

co mponents that are improperly designed (e.g.

, enardo valves over pressurizing, failure of thief hatches

to reseat after over pressurizing) or equipment not maintained properly (e.g.

, thief hatch left open )

. For

example

, emissions from an enardo valve on a condensate tank vent line, operating in the full or

partially open position due to excessive tank vapor pressure that exceeds the pressure setting of the

enardo valve, are not considered to be fugitive emissions.

Spe ciated hydrocarbon emission rates can be estimated by multiplying the total hydrocarbon emission

rates obtai ned from the table above by actual measured weight fractions or by using the values listed in

the table below.

Speciated Fugitive Emission Factors

( Estimated weight fractions of THC emissions in each category)

Methane NMHC VOC C6 + Benzene Toluene Ethyl

Benzene Xylenes

light crude 0.613 0.387 0.292 0.02430 0.00027 0.00075 0.00017 0.00036

heavy crude 0.942 0.058 0.030 0.00752 0.00935 0.00344 0.00051 0.00372

gas production 0.92 0.080 0.035 0.00338 0.00023 0.00039 0.00002 0.00010

NOTES: 1. Emission factor = Speciated Emissions/Total Emissions

2. NMHC = Non

- methane hydrocarbons

3. VOC = Propane and heavier hydrocarbonsC6 S2 O&G Production Facilities Permitting Guidance

March 2010

Page 67 of 7 1

FUGITIVE EMISSIONS

- EXAMPLE CALCULATION

Given: 25 valves in light oil service

THC emission factor = 0.13 lb/component

- day

VOC weight fraction = 0.292

HAP weight fractions = 0.02430 + 0.00027 + 0.00075 + 0.00017 + 0.00036 = 0.0259

VOC emissions = 25 valves × 0.13 lb THC/valves

- day × 1 ton/2000 lb × 365 day/hr × 0.292 = 0.17 TPY VOC

HAP emissions = 25 valves × 0.13 lb THC/valves

- day × 1 ton/2000 lb × 365 day/yr × 0.0259 = 0.015 TPY total HAPs

INTERNAL COMBUSTION PUMPING UNIT ENGINE EMISSIONS

T he method for calculating engine emissions is to use emission factors provided by the engine

manufacturer, the maximum site

- rated horsepower and the annual operating hours.

PUMPING UNIT ENGINE EMISSIONS

- EXAMPLE CALCULATION

Given: Manufacturer’s NO

X emission factor = 2 g/hp

- hr

Maximum site

- rated horsepower = 250 hp

Annual operating hours = 8760

NO X emissions = (2.0 g/hp

- hr) × (250 hp) × (8760 hr/yr) × (ton/2000 lb) × (1 lb/453.6 g) = 4.8 TPY

For CO and VOC emissions the same calculations are used except the manufacturer’s EF for CO and VOC are used.

CONVERTING MOLE PERCENT TO WEIGHT PERCENT

Many emission estimation and calculation methods require weight percents to be used, rather than

mole percents. Most lab analyses list gas constituents in mole percents, however you can request the

lab provide both mole and weight percents.

You may download the Excel spreadsheet to convert mole percent to weight percent, at

http://d eq.state.wy.us/aqd/miscforms.aspC6 S2 O&G Production Facilities Permitting Guidance

March 2010

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# APPENDIX C

DEFINITIONSC6 S2 O&G Production Facilities Permitting Guidance

March 2010

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Air Contaminant

- shall mean dust, fumes, mist, smoke, other particulate matter, vapor, gas or any

combination of these; but shall not include steam or water vapor.

Air pollutants

- Also known as criteria pollutants, Air pollutant emissions which have ambient air

standards associated with them. Air pollutants include such emissions as volatile organic compounds

(VOC), nitrogen oxides (NOx), carbon monoxide (CO), sulfur dioxide (SO

2 ), hazardous air pollutants (HAP)

and others

.

Average Daily Production

- The qualified maximum total production of domestic crude petroleum and

petroleum condensates including natural gas liquids produced from a well during a certain period of

time (i.e. 1

- month, 1

- year) divided by the number of calendar days in the certain period during which

the well produced. For example, the average 30

- daily condensate production rate for well ABC is the

qualified maximum total condensate production during the 30

- day pe riod x(BBL) ÷ 30(days) = y(BPD). If

well ABC only produced 5 days out of the 30

- day period, then the average daily condensate production

rate for the well is x(BBL) ÷ 5(days) = y(BPD).

Closed System

– A vessel (treater, separator), pipeline, sales line, g athering line, collection line, field gas

supply or distribution line or any other vessel or line from which no vapors or liquids can exit through

open lines, holes, vents or valves unless those lines, holes, vents or valves are connected to another

closed system or to a source of continual and complete combustion, unless the vent or valve is a relief

device that is designed and intended to open only during emergency situations.

Completion

– An oil well shall be considered completed when the first new oil is produced through

wellhead equipment into lease tanks from the producing interval after the production string has been

run. A gas well shall be considered completed when the well is capable of producing gas through

wellhead equipment from the producing zone after the production string has been run.

Condensate

- Hydrocarbon liquid separated from natural gas that condenses (becomes liquid) due to

changes in temperature, pressure, or both, and remains liquid at standard conditions.

Custody Transfer

- The transfer of produced petroleum and/or condensate, after processing and/or

treatment in the producing operations, from storage vessels or automatic transfer facilities to pipelines

or any other forms of transportation.

Division

- The Department of Env ironmental Quality, Air Quality Division

First Date of Production

- The date permanent production equipment is in place and product is

consistently flowing to sales lines, gathering lines or storage tanks. Production occurring during well

completion acti vities which is routed to temporary production equipment is considered to occur prior to

the First Date of Production. If extended periods of time pass between zone completions but

production from initially completed zones is consistently flowing to perma nent production equipment,

the First Date of Production is the date when production from the initial zones began consistently

flowing to the permanent production equipment, even though more zones will be comp l eted later.

Fugitive Emissions (Fugitives)

- Air emissions which result from gas vapors escaping through and around

seals, packing, gaskets, threads, and other such pressure sealing connections.

Gas

– All natural gases and all hydrocarbons not defined as oil.C6 S2 O&G Production Facilities Permitting Guidance

March 2010

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Gas Well

– A well, the principal product ion of which

, at the mouth of the well, is gas, as defined by the

Wyoming Conservation Law.

Grand fathered

- A facility, installation or site which was built or in service before May 29, 1974 and that

has not been physically or operationally changed, caus ing an increase in any pollutant (to which any

state standard applies) or causing the emission of a new pollutant. (Modifications which could eliminate

grandfather status are increasing production rate by fracturing, acidizing, recompletion of a zone,

cha nge in artificial lift methods, bringing new wells into a central battery or a waterflood response. Also

such things as installing an engine, increasing horsepower, change in burner ratings. This list is not all

inclusive and judgment should be used to d etermine appropriate status.)

HAP

- Hazardous air pollutant, found in Section 112(b) of the Clean Air Act is a list of 188 contaminants

with the classification “hazardous air pollutant”. Typical hazardous air pollutants include benzene,

toluene, ethyl

- be nzene, xylene, n

- hexane, formaldehyde, methanol and others.

Major Emitting Facility

- A facility which either has the potential to emit 250 TPY or more of any one

regulated a i r pollutant or is a named facility and has the potential to emit 100 TPY or more of any one

regulated air pollutant.

Major Source

- A source which emits either 100 TPY or more of a regulated air pollutant, 10 TPY or more

of a hazardous air pollutant, or 25 TPY or more of the total hazardous air pollutants.

Modified Facility

- An existing facility becomes modified once production streams or production

equipment associated with another well or wells is added to or tied into it. The date modification occurs

to an existing facility is the First Date of Production for the added well o r the date the production

streams associated with an additional well or wells are tied into equipment at the existing facility.

Examples of modified facilities not involving new wells or added production from other wells are:

An existing well facility is completed in additional production zones resulting in increased

production and/or emissions at the facility greater than those previously permitted.

Existing production equipment is replaced with larger equipment, resulting in increased

potential or actual emissions.

Oil

– Crude petroleum oil and any other hydrocarbons, regardless of gravities, which are produced at

the well in liquid form by ordinary production methods, and which are not the result of condensation of

gas before or after it leaves the rese rvoir.

Oil Well

– A well, th e principal production of which, at the mouth of the well

, is oil, as defined by the

Wyoming Conservation Law.

PAD

- A PAD facility is a location where more than one well and/or associated production equipment

are located, wh ere some or all production equipment is shared by more than one well or where well

streams from more than one well are routed through individual production trains located at the same or

contiguous and adjacent location. If the production streams or produc tion equipment associated with

one or more wells is added to an existing single well facility, that location is then considered to be a PAD

facility. A single well becomes a multiple well or PAD facility upon the First Date of Production of an

additional well at the location or on the day production streams associated with an additional well or

wells from separate locations are routed to the single well facility

.C6 S2 O&G Production Facilities Permitting Guidance

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Potential to Emit

- The maximum capacity of a stationary source to emit any air pollutant unde r its

physical and operational design. Any physical or operational limitation on the capacity of a source to

emit an air pollutant, including air pollution control equipment and restrictions on hours of operation or

on the type or amount of material combu sted, stored or processed, shall be treated as part of its design

if the limitation is enforceable by the EPA and the Division.

Recompletion

– Any downhole operation in an existing oil or gas well that is conducted to establish

production of oil or gas fr om any geological interval not currently completed or producing in said

existing oil or gas well.

Single Well Facility

– A single well facility is one where production equipment is associated with only

one well. A single well becomes a multiple well or P AD facility upon the First Date of Production of an

additional well at the location or on the day production streams associated with an additional well or

wells from separate locations are routed to the single well facility.

Spud

– The commencement of operations for the first boring of a hole for the drilling of an oil, gas or

injection well. This includes setting conductor casing.

Synthetic Minor

- “Synthetic Minor” sources are sources that do the following types of things to limit

emission rates below 100 TPY: 1) limit operating hours of a source or 2) limit production rates such that

source emissions are less than 100 TPY.

VOC

- Volatile organic compound means any organic compound which participates in atmospheric

photoch emical reactions; typically considered C

3 + or Non

- methane/ethane hydrocarbon vapors.

VOC Weight Percent

- This is the weight of the volatile organic compounds, expressed as a percent, as

compared to the total weight of the compounds in a gas stream. (Thi s should not be confused with the

volume or mole percent of a gas stream, which is usually how it is expressed in a lab analysis of a gas.)

Wildcat Well

– Any oil or gas well designated as a wildcat well by the Wyoming Oil and Gas Conservation

Commission. Wildcat wells are wells outside known fields or new wells which are determined by the

Commission to have discovered oil or gas in a pool not previously proven productive.

Workover

– Any downhole operation in an existing oil or gas well that is designed to sustain, restore or

increase the production rate or ultimate recovery in a geologic interval currently completed or

producing in said existing oil or gas well. Workover includes but is not limited to: acidizing,

reperforating, fracture treating, sand/p araffin removal, casing repair, squeeze cementing or setting

bridge plugs to isolate water productive zones from oil or gas productive zones or any combination

thereof. Workover does not mean the routine maintenance, repair or replacement of downhole

equi pment such as rods, pumps, tubing, packers or other mechanical devices.

Worst case

- A situation allowed in air permitting in the State of Wyoming where a facility, site or

source (which is representative of all the facilities, sites or sources within a designated field area) may

be used to represent the worst air emissions for the field area sources.

Wyoming Environmental Quality Act

- Wyoming Statute, Title 35 “Public Hea l th and Safety”, Chapter 11

“Environmental Quality” which provides the authority for the rules and regulations of the Air Quality

Division.