HomeMy WebLinkAbout20133203.tiffSTATE OF COLORADO
John W. Hickenlooper, Governor
Christopher E. Urbina, MD, MPH
Executive Director and Chief Medical Officer
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
Located in Glendale, Colorado
hffp://www.cdphe.state.co.us
Weld County Clerk & Recorder
1402 N 17th Ave
Greeley, CO 80631
November 7, 2013
Dear Sir or Madam:
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
RECEIVED
WELD COUNTY
COMMISSIONERS
Colorado Department
of Public Health
and Environment
On November 10, 2013, the Air Pollution Control Division will publish a public notice for Bonanza Creek
Energy Operating Company LLC — Seventy Holes J-F-5HZ Production Pad, in the The Greeley Tribune. A
copy of this public notice and the public comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public
copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet
must be available for public inspection for a period of thirty (30) days from the date the public notice is
published. Please send any comment regarding this public notice to the address below.
Regards,
7;
(:yam r
Colorado Dept. of Public Health & Environment
APCD-S S -B 1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
P iicR tw
11 I7l179
2013-3203
STATE OF COLORADO
John W. Hickenlooper, Governor
Christopher E. Urbina, MD, MPH
Executive Director and Chief Medical Officer
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
Located in Glendale, Colorado
http://www.cdphe.state.co.us
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Colorado Department
of Public Health
and Environment
Website Title: Bonanza Creek Energy Operating Company LLC — Seventy Holes J-F-5HZ Production Pad —
Weld County
Released To: The Greeley Tribune
On: November 7, 2013
Published: November 10, 2013
PUBLIC NOTICE OF A PROPOSED PROJECT
OR ACTIVITY WARRANTING PUBLIC COMMENT
Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado
Air Pollution Control Division for the following source of air pollution:
Applicant: Bonanza Creek Energy Operating Company LLC
Facility: Seventy Holes J-F-5HZ Production Pad
oil and gas exploration and production site
SESW Section 5, T4N, R62W, approximately 10 miles east of Kersey
Weld County
The proposed project or activity is as follows: The applicant proposes to permit a liquid loadout, pneumatic
pumps and associated fugitives at a new oil and gas exploration and production facility.
The Division has determined that this permitting action is subject to public comment per Colorado Regulation No.
3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section IB.C.I.a
(25 tpy in a non -attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 13WE1295 have been filed
with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the
Division's website at www.colorado.gov/cdphe/AirPublicNotices
The Division hereby solicits submission of public comment from any interested person concerning the ability of
the proposed project or activity to comply with the applicable standards and regulations of the Commission. The
Division will receive and consider written public comments for thirty calendar days after the date of this Notice.
Any such comment must be submitted in writing to the following addressee:
Rebecca Vasil
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
13WE1295
Issuance 1
DATE ISSUED:
ISSUED TO: Bonanza Creek Energy Operating Company, LLC
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Seventy Holes J-F-5HZ Production Pad, located in the
SESW Sec. 5 T4N R62W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
Truck
Loadout
002
Truck loadout of condensate and produced water. Emissions
from the loadout are not controlled.
FUG
003
Equipment leaks (fugitive VOCs) from a natural gas exploration
and production facility.
Pneumatic
Pumps
004
Two (2) heat trace circulation pumps (Sandpiper, G1F, and
serial number: to be provided) rated each at 600
scf/hr.Emissions from these pumps are controlled by an
enclosed flare.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO
AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than
fifteen days after issuance of this permit, by submitting a Notice of Startup form to
the Division. The Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup
of the permitted source is a violation of Air Quality Control Commission (AQCC)
Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) after issuance of this permit, compliance with
the conditions contained in this permit shall be demonstrated to the Division. It is the
owner or operator's responsibility to self -certify compliance with the conditions. Failure to
AIRS ID: 123/9A5E
Page 1 of 11
Fugitive SM/M Version 2012-2
olor- Depa en .f P,•li Health and Environment
it Pollution Control Division
demonstrate , '^P ce i rn da ^'.rA,a esult evocation of the permit.
(Reference: Regulation No. 3, Part B, II.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the date
on which such construction or activity was scheduled to commence as set forth in the
permit application associated with this permit; (ii) discontinues construction for a period
of eighteen months or more; (iii) does not complete construction within a reasonable
time of the estimated completion date. The Division may grant extensions of the
deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
III.F.4.)
4. Point 003: The operator shall complete all initial compliance testing and sampling as
required in this permit and submit the results to the Division as part of the self -
certification process. (Reference: Regulation No. 3, Part B, Section III.E.)
5. Point 004: The following information shall be provided to the Division within fifteen (15)
days after issuance of permit.
• manufacturer
• model number
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III.E.)
6. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO„
VOC
CO
Truck loadout
002
---
7.4
---
Point
FUG
003
---
4.7
---
Fugitive
PUMP -1
004
0.51
5.7
2.8
Point
See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0
tpy.
Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)
from each emission unit, on a rolling twelve (12) month total. By the end of each month
AIRS ID: 123/9A5E
Page 2 of 11
Health and Environment
it Pollution Control Division
a new twelve- ast$ • al aton the,-"ious twelve months' data.
The permit holder shall calculate emissions each month and keep a compliance record
on site or at a local field office with site responsibility, for Division review. This rolling
twelve-month total shall apply to all permitted emission units, requiring an APEN, at this
facility.
8. Point 003: The operator shall calculate actual emissions from this emissions point
based on representative component counts for the facility with the most recent gas and
liquids analyses, as required in the Compliance Testing and Sampling section of this
permit. The operator shall maintain records of the results of component counts and
sampling events used to calculate actual emissions and the dates that these counts and
events were completed. These records shall be provided to the Division upon request.
9. Point 004: The emission points in the table below shall be operated and maintained with
the control equipment as listed in order to reduce emissions to less than or equal to the
limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility
Equipment ID
AIRS Point
Control Device
Pollutants
Controlled
Pneumatic
Pumps
004
Combustor
VOC
PROCESS LIMITATIONS AND RECORDS
10. Point 002 and Point 004: This source shall be limited to the following maximum
processing rates as listed below. Monthly records of the actual processing rate shall be
maintained by the owner or operator and made available to the Division for inspection
upon request. (Reference: Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility
Equipment
ID
AIRS
Process Parameter
Annual
ii
Truck
Loadout
002
Condensate Loading
96,725
BBL/yr
Pneumatic
Pumps
004
Venting of natural gas used to drive
pneumatic pumps
10.6
MMscf/yr
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on
the previous twelve months' data. The permit holder shall calculate throughput each
month and keep a compliance record on site or at a local field office with site
responsibility, for Division review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
11. Point 004: Visible emissions shall not exceed twenty percent (20%) opacity during
normal operation of the source. During periods of startup, process modification, or
adjustment of control equipment visible emissions shall not exceed 30% opacity for more
than six minutes in any sixty consecutive minutes. Emission control devices subject to
AIRS ID: 123/9A5E
Page 3 of 11
Health and Environment
it Pollution Control Division
Regulation 7ns �rdic X1'& shall:.Ax-. e no visible emissions.
(Reference: Regulation No. 1, Section II.A.1. & 4.)
12. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
13. Point 004: The permit number and AIRS ID point number (e.g. 123/4567/890) shall be
marked on the subject equipment for ease of identification. (Reference: Regulation
Number 3, Part B, III.E.) (State only enforceable)
14. Point 002: This source is located in an ozone non -attainment or attainment -
maintenance area and is subject to the Reasonably Available Control Technology
(RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to
truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E)
15. Point 003: Minor sources in designated nonattainment or attainment/maintenance areas
that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall
apply Reasonably Available Control Technology (RACT) for the pollutants for which the
area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B,
III.D.2.a). This requirement to apply RACT shall be satisfied by installing/implementing
the following emission controls:
a. Directed Inspection & Maintenance as described below shall satisfy the
requirement to apply RACT.
i. For leak screening, auditory/visual/olfactory inspection (AVO) will be
performed on a semi-annual basis.
ii. For each leak found in the AVO inspection, a gas detector shall be
used to determine the size of the leak. The gas detector shall be
regularly calibrated. Component leaks greater than 10,000 ppm shall
be managed in accordance with Item (vi) below, unless it is unfeasible
to make the repair without shutting down the affected operation of the
facility. For such component leaks that require a shutdown to be
repaired, repair shall occur during the first shutdown of the affected
operation after the leak is discovered.
iii. For repair, valves adjacent to the equipment to be repaired will be
closed if practicable, minimizing the volume released.
iv. Repaired components shall be re -screened to determine if the leak is
repaired.
v. The following records shall be maintained for a period of five years:
• The name of the site screened via AVO inspection and the
name of the inspector.
• Components evaluated with the gas detector.
• Repair methods applied.
• Dates of the AVO screenings, gas detector calibrations,
attempted repairs, successful repairs, repair delays, and post -
repair screenings.
vi. Leaks shall be repaired as soon as practicable, but no later than 15
calendar days after detection, unless it is technically or operationally
AIRS ID: 123/9A5E Page 4 of 11
Health and Environment
r Pollution Control Division
si th< -...;` ithin " calendar days. Records
documenting the rationale shall be maintained if it is technically or
operationally infeasible to make the repair within 15 calendar days.
OPERATING & MAINTENANCE REQUIREMENTS
16. Point 004: Upon startup of these points, the owner or operator shall follow the most
recent operating and maintenance (O&M) plan and record keeping format approved by
the Division, in order to demonstrate compliance on an ongoing basis with the
requirements of this permit. Revisions to your O&M plan are subject to Division approval
prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
17. Point 003: Within one hundred and eighty days (180) after issuance of this permit, the
operator shall complete a hard count of components at the source and establish the
number of components that are operated in "heavy liquid service", "light liquid service",
"water/oil service" and "gas service". The operator shall submit the results to the
Division as part of the self -certification process to ensure compliance with emissions
limits.
Periodic Testing Requirements
18. Point 003: On an annual basis, the owner or operator shall complete an extended gas
analysis of gas samples that are representative of volatile organic compounds (VOC)
and hazardous air pollutants (HAP) that may be released as fugitive emissions. This
extended gas and liquids analyses shall be used in the compliance demonstration as
required in the Emission Limits and Records section of this permit.
ALTERNATE OPERATING SCENARIOS
19. Point 004: This pump may be replaced with a like -kind pump in accordance with the
requirements of Regulation 3, Part A, Section IV.A and without applying for a revision to
this permit or obtaining a new construction permit. A like -kind replacement pump shall
be the same make, model and capacity as authorized in this permit.
20. Point 004: The owner or operator shall maintain a log on -site or at a local field office to
contemporaneously record the start and stop dates of any pump replacement, the
manufacturer, model number, serial number and capacity of the replacement pump.
21. Point 004: All pump replacements installed and operated per the alternate operating
scenarios authorized by this permit must comply with all terms and conditions of this
construction permit.
ADDITIONAL REQUIREMENTS
22. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, II.C)
a. Annually by April 301h whenever a significant increase in emissions occurs as
follows:
AIRS ID: 123/9A5E Page 5 of 11
Fora , a • a
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in
ozone nonattainment areas emitting less than 100 tons of VOC or NO, per
year, a change in annual actual emissions of one (1) ton per year or more or five
percent, whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions
of five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less,
above the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of
control equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
23. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by
virtue of a relaxation in any permit condition. Any relaxation that increases the potential
to emit above the applicable Federal program threshold will require a full review of the
source as though construction had not yet commenced on the source. The source shall
not exceed the Federal program threshold until a permit is granted. (Regulation No. 3
Part D).
GENERAL TERMS AND CONDITIONS:
24. This permit and any attachments must be retained and made available for inspection
upon request. The permit may be reissued to a new owner by the APCD as provided in
AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership
and the submittal of a revised APEN and the required fee.
25. If this permit specifically states that final authorization has been granted, then the
remainder of this condition is not applicable. Otherwise, the issuance of this construction
permit does not provide "final" authority for this activity or operation of this source. Final
authorization of the permit must be secured from the APCD in writing in accordance with
the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section
III.G. Final authorization cannot be granted until the operation or activity commences
and has been verified by the APCD as conforming in all respects with the conditions of
the permit. Once self -certification of all points has been reviewed and approved by the
Division, it will provide written documentation of such final authorization. Details for
obtaining final authorization to operate are located in the Requirements to Self -
Certify for Final Authorization section of this permit.
26. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the owner or operator and is conditioned upon conduct of the activity, or
Health and Environment
it Pollution Control Division
AIRS ID: 123/9A5E Page 6 of 11
olor. l Depa en .f P
Health and Environment
r Pollution Control Division
construction, iF ^"^ n = xt =p"• n of •_ as«re<:-, in at ance with this information
and with representations made by the owner or operator or owner or operator's agents.
It is valid only for the equipment and operations or activity specifically identified on the
permit.
27. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with
the provisions of Section 25-7-114.5(7)(a), C.R.S.
28. Each and every condition of this permit is a material part hereof and is not severable.
Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire
permit and upon such occurrence, this permit shall be deemed denied ab initio. This
permit may be revoked at any time prior to self -certification and final authorization by the
Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality
Control Act and regulations of the Air Quality Control Commission (AQCC), including
failure to meet any express term or condition of the permit. If the Division denies a
permit, conditions imposed upon a permit are contested by the owner or operator, or the
Division revokes a permit, the owner or operator or owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
29. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
30. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of the AQCC may result in administrative,
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By:
Rebecca Vasil
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Bonanza Creek Energy Operating
Company, LLC
AIRS ID: 123/9A5E
Page 7 of 11
olor- t Depa - en
Notes to Permit Holder `' me o .e an
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 3, Part A, Section VI.B.)
2) The emission limits contained in this permit are based on the consumption rates requested in the
permit application. These limits may be revised upon request of the owner or operator providing
there is no exceedance of any specific emission control regulation or any ambient air quality
standard. A revised air pollution emission notice (APEN) and complete application form must be
submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written notice
to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions
Regulation. See:
http://www.cdphe.state.co. us/req ulations/a i rregs/100102agcccommonprovision sreq. pdf.
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
P
Health and Environment
r Pollution Control Division
AIRS
Point
Pollutant
CAS #
BIN
Uncontrolled
Emission
Rate
(lb/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
002
n -Hexane
110543
C
482
NO
482
Benzene
71432
A
78
YES
78
Toluene
108883
C
44
NO
44
Ethylbenzene
100414
C
2
NO
2
Xylenes
1330207
C
10
NO
10
AIRS
Point
Pollutant
CAS #
BIN
Uncontrolled
Emission
Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate
(Ib/yr)
003
Benzene
71432
A
43
No
43
Toluene
108883
C
129
No
129
Ethylbenzene
100414
C
30
No
30
Xylenes
1330207
C
133
No
133
n -Hexane
110543
C
207
No
207
AIRS ID: 123/9A5E
Page 8 of 11
IicsHealth and Environment
it Pollution Control Division
AIRS
Point
CAS #
Pollutant
BIN
Uncontrolled
Emission Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (lb/yr)
004
71432
Benzene
A
821
YES
41
108883
Toluene
C
731
NO
36
1330207
Xylenes
C
312
NO
16
110543
n -Hexane
C
4296
YES
215
100414
Ethylbenzene
C
65
NO
4
5) The emission levels contained in this permit are based on the following emission factors:
Point 002:
CAS
Pollutant
Emission Factors
Uncontrolled
lb/1000 gal
loaded
-
Source
VOC
3.62
AP -42
71432
Benzene
0.0191
Wt%
The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1
(version 1/95) using the following values:
L = 12.46*S*P*M/T
S = 0.6 (Submerged loading: dedicated normal service)
P (true vapor pressure) = 5.86 psia
M (vapor molecular weight) = 43.27 Ib/Ib-mol
T (temperature of liquid loaded) = 524°R
The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by
multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor.
Point 003:
Component
Gas Service
Heavy Oil
Light Oil
SWater/Oil
ervi
Service
Connectors
494
0
208
153
Flanges
51
0
137
72
Open-ended Lines
29
0
14
5
Pump Seals
0
0
0
0
Valves
83
0
53
28
Other*
15
0
0
2
VOC Content (wt.
fraction)
0.3331
0.0000
0.9944
1.0000
Benzene Content (wt.
fraction)
0.0012
0.0000
0.0064
0.0012
Toluene Content (wt.
fraction)
0.0011
0.0000
0.0281
0.0003
Ethylbenzene (wt
0.0001
0.0000
0.0070
0.0001
AIRS ID: 123/9A5E
Page 9 of 11
f P Iic'Health and Environment
it Pollution Control Division
fraction)
an ,i,
Xylenes Content (wt.
fraction)
0.0005
0.0000
0.0311
0.0001
n -hexane Content (wt.
fraction)
0.0063
0.0000
0.0305
0.0001
*Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms,
drains, dump arms, hatches, instrument meters, polish rods and vents
TOC Emission Factors (kg/hr-component):
Component
Gas Service
Heavy Oil
Light Oil
Water/Oil
Service
Connectors
2.0E-04
7.5E-06
2.1E-04
1.1E-04
Flanges
3.9E-04
3.9E-07
1.1E-04
2.9E-06
Open-ended Lines
2.0E-03
1.4E-04
1.4E-03
2.5E-04
Pump Seals
2.4E-03
NA
1.3E-02
2.4E-05
Valves
4.5E-03
8.4E-06
2.5E-03
9.8E-05
Other
8.8E-03
3.2E-05
7.5E-03
1.4E-02
Source: EPA -453/R95-017
Compliance with emissions limits in this permit will be demonstrated by using the TOC emission
factors listed in the table above with representative component counts, multiplied by the VOC content
from the most recent gas and liquids analyses.
Point 004:
AIRS
Point
CAS #
Pollutant
Emission Factors
- Uncontrolled
lb/MMscf vented
Emission Factors
- Controlled
lb/MMscf vented
Source
004
VOC
21,505
21,505
All emission factors
are based on the
displacement
equation and the
wet gas analysis.
108883
Toluene
70
70
1330207
Xylenes
30
30
110543
n -Hexane
409
409
71432
Benzene
78
78
The displacement equation can found in "EPA Emission Inventory Improvemen Program Publication:
Volume II, Chapter 10 - Displacement Equation (10.4-3)."
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the
most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division at
(303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of:
VOC, n -Hexane
AIRS ID: 123/9A5E
Page 10 of 11
Health and Environment
it Pollution Control Division
NANSR
yntfi�Mika&rca■■� ■ m
VOC
MACT HH
Area Source Requirements: Not Applicable
NSPS KKK
Not Applicable
NSPS OOOO
Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A — Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A —Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A — Subpart Z
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart 777Z — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
9) An Oil and Gas Industry Construc ion Permit Self -Certification Form is included with this permit
packet. Please use this form to complete the self -certification requirements as specified in the permit
conditions. Further guidance on self -certification can be found on our website at:
http://www.cdphe.state.co.us/ap/oilqaspermittinq. htm I
AIRS ID: 123/9A5E Page 11 of 11
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The dale of interest for determining whether the source is new or modified therefore November 20, 2007 (the dale of lie 6hour ozone NA area designation),I, ,n
NSPS KKK: Equipment Leaks of VOC from onshore natural gas processing plants. Affected facilities at onshore natural gas facilities (any processing site engaged in the extraction of natural gas liquids from field
gas, fractionation of mined natural gas liquids (NGLs) or both).
Is this source al a'natural gas processing plant?" > .
Is this source subject to NSPS KKK?
NSPS 0000: standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution. For fugitive emissions an natural gas processing plants subject to HOPS 0000. This subpart
establishes emission standards and compliance schedules for the control of volatile organic compounds (VOC) and sulfur dioxide (SO2) em ns from affected facilities that commence construction,
modification or reconstruction after August 2] 2011. is
.HE lF_l .AFTE THE ` GTE:F 3I 2011 .JC EWENIC I' AN
PRIOR (.v.T [K 25 JO A SOURCE
IF MODIFYING
INGA ENCASE' nl
NAPS ERR GITCE: APMIGHT MAKE OI NEWS SOURNS CES
I THEFUGITIVES
AUGsSTF2320GE a ELO IC DATE O.Er.! 5 WIrNBJ T :HH OSEE
, IT yrvM�JRC EOAJSE R.E:
FKFS94� AFEN MIAPES BECAUSECFNEPS aW RC. HE TEN H N.N... ?. SU WE VOW NEED'PT T (VIEW WWI A NJ APES t_E NEW I.. 14C EMISSIONS BECAUSE WHIC. IMS
FUGITIVESsis4 Eh WturlER proses g anF5 EKE AND THENEW .D._a NILa =J..._., T. .E`.-, OtO. PLEAT. R_`Aa3,:TH AND INDICATE1...'.E G_R.I ..'HIa�H P^vINTL V_.rF. T:J JYniCI't.�S
Is his source at a 'natural gas 0000? paid?' h..
Is this source sulked to NSPS OOOO? E..
Section 0.0: If facility if a natural gas processing plant located in nonatlalnment area, then subject to Section 0.G.
Is this source at a'natural gas processing plant?' t o
MACT HH: N facility is MAJOR source for HAP at a natural gas processing plant ONLY (summation of HAPS of dehydrators and fugitives), then fugitive emissions are subject to MACT HH.
Is this facility Considered MAJOR for HAPS? N.,
Is this source subject to MALT HH? tip.
I
C
C
C
C
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name:
Bonanza Creek Energy Operating Company, LLC
Permit Number:
13WE1295
Source Name:
Seventy Holes J-F-5HZ Production Pad
Source Location:
SESW Sec. 5 T4N R62W, Weld County (non -attainment)
Equipment Description:
Truck Loadout
AIRS ID:
123-9A5E-002
Review Date:
March 20th 2013
Review Engineer:
Rebecca Vasil
Section 2 — Action Completed
X
CP1
Modification
APEN Required/Permit Exempt
Final Approval
Transfer of Ownership
APEN Exempt/Permit Exempt
Section 3 — Applicant Completeness Review
Was the correct APEN submitted for this source type?
X
Yes
No
Is the APEN signed with an original signature?
X
Yes
No
Was the APEN filled out completely?
X
Yes
No
Did the applicant submit all required paperwork?
X
Yes
No
Did the applicant provide ample information to determine emission rates?
X
Yes
No
If you answered "no" to any of the above, when did you mail an
Information Request letter to the source?
On what date was this application complete?
January 17th 2013
Section 4 — Source Description
AIRS Point
Equipment Description
002
Truck Condensate Loadout
Is this a portable source?
Yes
X
No
Is this location in a non -attainment area for any criteria
pollutant?
X
Yes
No
If "yes", for what pollutant?
PM,()
CO
X
Ozone
Is this location in an attainment maintenance area for
any criteria pollutant?
Yes
X
No
If "yes", for what pollutant?
(Note: These pollutants are subject to minor source
RACT per Regulation 3, Part B, Section III.D.2)
PM10
CO
Ozone
Is this source located in the 8 -hour ozone non -
attainment region? (Note: If "yes" the provisions of
Regulation 7, Sections XII and XVII.C may apply)
X
Yes
No
Is this source located at an oil and gas exploration site?
X
Yes
No
Page l
If yes, does this source load less than 10,000 gallons of
crude oil per day on an annual average, splash fill less
than 6750 bbl of condensate (hydrocarbons that have
an API gravity of 40 degrees or greater) per year or
submerged fill less than 16,308 bbl of condensate per
year?
Yes
X
No
Is this source located at a facility that is considered a
major source of hazardous air pollutant (HAP)
emissions?
Yes
X
No
Will this equipment be operated in any NAAQS
nonattainment area?
X
Yes
No
Does this source load gasoline into transport vehicles?
Yes
X
No
Section 5 — Emission Estimate Information
AIRS Point
Emission Factor Source
002
AP -42: Chapter 5.2, Equation 1
L = 12.46*S*P*M/T
L = loading losses in lb per 1000 gallons loaded
S = Saturation Factor
P = true vapor pressure of liquid loaded [psia]
M = molecular weight of vapors [lb/lb-mole]
T = temperature of bulk liquid loaded [deg. R]
Did the applicant provide actual process data for the emission inventory?
X
Yes
No
Basis for Potential to Emit (PTE)
AIRS Point
Process Consumption/Throughput/Production
002
96,725 BBL per year condensate loaded
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point
Process Consumption/Throughput/Production
002
96,725 BBL per year condensate loaded
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
002
96,725 BBL per year condensate loaded
Does this source use a control device?
Yes
X
No
Section 6 — Emission Summary
(tons per year)
Point
NO„
VOC
CO
Single HAP
HAP
PTE:
002
---
7.4
---
0.24 (n -hexane)
.32
Uncontrolled point
source emission rate:
002
---
7.4
---
0.24 (n -hexane)
.32
Permitted point source
emission rate:
002
---
7.4
---
0.24 (n -hexane)
.32
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled Emission
Ibl r
Rate ( y )
Benzene
71432
A
77.73
Yes
N/A
n -Hexane
110543
C
481.58
No
N/A
Page 2
Toluene
108883
C
44.23
No
N/A
Xylenes
1130207
C
10.46
No
N/A
Note: Regulation 3, Part A, Section ll.B.3.b APEN emission reporting requirements for non -criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Section 8 —Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory
standard?
Yes X No
Section 9 — Source Classification
Is this a new previously un-permitted source?
X
Yes
No
What is this facility classification?
True
Minor
X
Synthetic
Minor
Major
Classification relates to what programs?
X
Title V
PSD
X
NA NSR
X
MACT
Is this a modification to an existing permit?
Yes
X
No
If "yes" what kind of modification?
Minor
Synthetic
Minor
Major
Section 10 — Public Comment
Does this permit require public comment per CAQCC Regulation 3?
Yes
X
No
If "yes", for which pollutants? Why?
For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)?
Yes
X
No
For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)?
Yes
X
No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)?
X
Yes
No
Section 11 — Modeling
Is modeling required to demonstrate compliance with National Ambient
Air Quality Standards (NAAQS)?
Yes X No
AIRS Point
Section 12 —Regulatory Review
Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide
002
Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of
the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in any
sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 4.)
Regulation 2 — Odor
002
Section LA - No person, wherever located, shall cause or allow the emission of odorous air
contaminants from any single source such as to result in detectable odors which are
measured in excess of the following limits: For areas used predominantly for residential or
commercial purposes it is a violation if odors are detected after the odorous air has been
diluted with seven (7) or more volumes of odor free air.
Page 3
Regulation 3 -APENs, Construction Permits, Operating Permits, PSD
002
Criteria Pollutants:
Applicant is required to file an APEN since emissions exceed 1 ton per year VOC
Part B — Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 2.0 TPY threshold (Reg. 3, Part B, Section II.D.3.a)
Part B, III.D.2 - RACT requirements for new or modified minor sources
This section of Regulation 3 requires RACT for new or modified minor sources located in
nonattainment or attainment/maintenance areas. This source is/is not located in the 8 -hour
ozone nonattainment area, but not the 1 -hour ozone area.
The date of interest for determining whether the source is new or modified is therefore
November 20, 2007 (the date of the 8 -hour ozone NA area designation). Operator is using
0.6 saturation factor (submerged fill), therefore, RACT requirements are satisfied.
Regulation 6 - New Source Performance Standards
002
No applicable subpart. This facility is not a bulk gasoline terminal.
Regulation 7 — Volatile Organic Compounds
002
No sections apply. Per Regulation 7, Section VI.C, a terminal is defined as a petroleum
liquid storage and distribution facility that has a daily average throughput of more than
76,000 liters of gasoline (20,000 gallons), which is loaded directly into transport vehicles.
This facility is neither a terminal, nor a bulk plant per definitions in Reg 7, Section VI.C.
Regulation 8 — Hazardous Air Pollutants
002
MACT EEEE:
Not subject because minor source of HAPs
Section 13 — Aerometric Information Retrieval System Coding Information
Point
Process
Process
Description
Process/
throughput
Limit
Emission
Factor
Pollutant/
CAS #
Fugitive
(Y/N)
Emission
Factor
Source
Control
(%)
002
01
Truck Condensate
Loadout
96,725
BBL/yr
3.62
lb/1,000
gallon
throughput
VOC
No
AP -42
0
SCC
40600132: Crude Oil: Submerged Loading (Normal Service)
Page 4
Section 14 — Miscellaneous Application Notes
AIRS Point
002
Truck Condensate Loadout
Units
Basis
S
0.6
Submerged loading: AP -42
Table 5.2-1
P
5.86
Psia
AP -42 Figure 7.1-13b and
RVP of tank liquid
M
43.27
Lb/lb-mole
Based on extended natural
gas sample
T
524
Deg R
Based on source's
knowledge of bulk liquid
temperature
L
3.62
Lb/10^3 gal
Value is used to calculate
annual emissions of VOC
1.52E-01
Lb/bbl
AP -42: Chapter 5.2
Equation 1
L = 12.46*S*P*M/T
L = loading losses in lb per 1000 gallons loaded
S = Saturation Factor
P = true vapor pressure of liquid loaded [psia]
M = molecular weight of vapors [lb/lb-mole]
T = temperature of bulk liquid loaded [deg. R]
L 3.621b/10^3 gal
1.52E-01 lb/bbl
Annual requested Throughput 4062450ga1/yr
Annual requested VOC emissions 146961b/yr
7.35tpy
Page 5
Division Information
Engineer:
Rebecca Vasil
Control Engineer:
Chns Laplante
Review Date:
03/20/2013
Application Date:
01/17/2013
Facility Identifiers
Permit No.
13WE1295
AIRs
County #
123 Weld
Facility#
9A5E
Point #
004
Facility Equipment ID
Pneumatic Pump
Section 01: Administrative Information
Company Name:
Bonanza Creek Energy Operating Company, LLC
Source Name:
Seventy Holes J-F-5HZ Production Pad
i
Source Location:
SSW Sec. 5 T4N R62W
E
SIC:
1311
Elevation (feet)
5439
Mailing
Address
Address 1:
Address 2:
City, State Zip:
Bonanza Creek Energy Operating Company, LLC
410 17th St. suite 1500
Denver, CO 80202
Person To
Contact
Name:
Phone:
Fax:
Email:
Peg Young
720-440-6133
720-279-2331
pyoung@ElonanzaCrkcom
Potentially Located within EAC - determine attainment status of NOx and VOC
Attainment Status
PM10
Attainment
PM2.5
Attainment
SOx
Attainment
NOx
Nonattainment
V0C
Nonattainment
CO
Attainment
Section 02: Requested Action
X
New permit/ newly reported emission source
Request Mod - Change fuel/equipment
Request Mod - Change permit limit
Request Mod- Change company name
Request Mod - Transfer of ownership
Request Mod - Other
X Request to limit HAPs with federally enforceable limits
Issuance Number: 1
Add(' Info
and notes:
Section 03: General Facility Information
For existing sources, operation began on:
10/19/2012
For New/recon sources, projected startup date:
1/1/1900
Normal hours of operation:
24 hrs/day
7 days/wk
52 weeks/yr
General description of equipment
purpose:
This emission unit is used fo heat trace circulation and
pit pumping.
Will this equipment be operated in any nonattainment area?' Yes
Section 04: Pump Information
Pump
Information
Manufacturer:
Sandpiper
Model Number:
G1F
Serial Number:
To Be Determined
Pump capacity
9.1 [gallons per minute pumped
Max. pump natural
gas consumption
1200
scf/hour used*
* There are 2 pumps each with a ga consumptio of 600scf/hour
Section 05: Emission Calculations
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10- Displacement Equation (10.4-3)
Ex=Q*MW *Xx /C
Ex = emissions of pollutant x
Q = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = 5G of gas " MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
Q
1200
scf/hr
MW
246
Ib/Ib-mol
Hours of Op.
9760
hours/yr
Requested Throughput
10.512 MMscf/yr
Component
mole%
MW
massfraction
Component
lb/hr
lb/yr
tpy
propane
92457
44.09
0.1657
propane
12.908
113076.670
56.538
isobutane
1.0014
58.12
0.0237
isobutane
1.843
16142.817
8.071
n -butane
2.9351
58.12
0.0693
n -butane
5.401
47314.543
23.657
isopentane
0.5716
72.15
0.0168
isopentane
1.306
11438.648
5.719
n -pentane
0.7253
72.15
0.0214
n -pentane
1.664
14574.471
7.287
n -hexane
0.1797
86.18
0.0063
n -hexane
0.490
4295.371
2.148
cyclohexane
0.0535
84.18
0.0018
cyclohexane
0.143
1249.133
0.625
Other hexane
0.2903
86.18
0.0102
Other hexanes
0.793
6950.996
3.475
heptanes
01565
100.21
0.0064
heptanes
0.497
4349.823
2.175
methylcycloh
00467
98.19
0.0019
methylcyclohe
0.145
1271.834
0.636
224 -IMP
00001
114.22
0.0000
224-TMP
0.000
3.168
0.002
Benzene
00379
78.11
0.0012
Benzene
0.094
821.092
0.411
Toluene
00296
92.14
0.0011
Toluene
0.083
730.904
0.365
Ethylbenzene
0.0022
106.17
0.0001
Ethylbenzene
0.007
64.784
0.032
Xylenes
00106
106.17
0.0005
Xylenes
0.036
312.143
0.156
C8+ Heavies
0.1092
114.23
0.0051
C8+ Heavies
0.395
3459.784
1.730
Mass Fraction VOC: 0.3313
Total 113.028
Total
113.028 tpy VOC
Notes
Mole y., MW and mass fractions from extended gas analysis dated 11/1/2012
CAB#
Total (Ib/yr)
Bin
Scenario A
Reportable?
n -hexane
110543
4295.4
C
Yes
224-TMP
540841
3.2
C
No
Benzene
71432
821.1
A
Yes
Toluene
108883
730.9
C
No
E -Benzene
100414
64.8
C
No
Xylenes
1330207
312.1
C
No
Resultant Emission Factors
VOC
Benzene
n -hexane
Toluene
E -Benzene
Xylenes
224-TMP
21504.583
78.110
408.616
69.530
6.163
29.694
0.301
lb/MMscf natural gas used
lb/MMscf natural gas used
lb/MMscf natural gas used
lb/MMscf natural gas used
lb/MMscf natural gas used
lb/MMscf natural gas used
lb/MMscf natural gas used
uid Loadin
drocarbon L
Permit 'amber:
Truck Loadout
Facility Equipment ID:
Section 02 — Requested Action (Check applicable request boxes)
Section 01 —Administrative Information
Request for NEW permit or newly reported emis
sting permit (check each box below that applies)
Request MODIFICATION to e
O V
M
U U
PR.
Source Name:
Change permit limit
uc
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Source Location
T
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O
U
N
410 17th Street, Suite 1500
00
Denver, Colorado
00
O
00
0.
Person To Contact:
720-279-2331
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Controlled Actual
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215
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Uncontrolled Actual
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Emission
Factor Source
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Emission Factor
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0.245 lb/hr-pump
0.047 Iblhr-pump
Control Equipment /
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Chemical Name
n -Hexane
Benzene
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