HomeMy WebLinkAbout20130918STATE 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
Weld County Clerk & Recorder
1402 N 17th Ave
Greeley, CO 80631
April 4, 2013
Dear Sir or Madam:
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
RECEIVED
APR 1 0 GYJ eh
WELD COUNTY
COMMISSIONERS
Colorado Department
of Public Health
and Environment
On April 8, 2013, the Air Pollution Control Division will publish a public notice for Bonanza Creek Energy
Operating Company LLC — Latham 14-2 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.
Colorado Dept. of Public Health & Environment
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
PaAd /nett/'ezd
it- /5=. c;)073
ecy !4 IlL
2013-0918
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 — Well Pad — Weld County
Released To: The Greeley Tribune
On: April 4, 2013
Published: April 8, 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: Latham 14-2 Production Pad
Well Pad
SWSW Sect T4N R63W
Weld County
The proposed project or activity is as follows: Source proposes a new well pad facility including condensate
tanks, two pneumatic pumps, and three pump jack engines.
The Division has determined that this permitting action is subject to public comment per Colorado Regulation No.
3, Part B, Section 11I.C due to the following reason(s):
• 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, including supplemental information, the Division's analysis, and a draft of
Construction Permit 12WE3095 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:
Peter Armington
Colorado Department o£ Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B I
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
FTSTATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
PERMIT NO:
12WE3095
CONSTRUCTION PERMIT
1876
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 Latham 14-2 Production Pad, located in SWSW Sec 2
T4N R63W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment ID
AIRS
Point
Description
El
004
One (1) Arrow Engine Company, Model A-62, Serial Number
To Be Determined, natural gas -fired, naturally aspirated,
4SRB reciprocating internal combustion engine, site rated at
80 horsepower at 1800 RPM. This engine shall be equipped
with a non -selective catalytic reduction (NSCR) system. This
emission unit powers a pump jack.
Truck
Loadout
005
Truck loadout of condensate. Emissions from the loadout
are not controlled.
FUG
006
Fugitive Emissions
Pnuematic
Pumps
007
One (1) water transfer pump, and one (1) heat trace
circulation pump, both Sandpiper G1F models, each rated at
600 scf/hr.
Point 004: This engine may be replaced with another engine in accordance with the
temporary engine replacement provision or with another Arrow Engine Company A-62
engine in accordance with the permanent replacement provision of the Alternate Operating
Scenario (AOS), included in this permit as Attachment A.
Point 007: This pump may be replaced with another pump in accordance with the provisions
of the Alternate Operating Scenario (AOS) in this permit.
AIRS ID: 123/9A7D/004-007
Page 1 of 19
NGEngine Version 2012-1
rado Department of Public Health and Environment
Air Pollution Control Division
TH :' I7G E CT TtlsALL 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
demonstrate compliance within 180 days may result in revocation 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. Points 004 & 007: The following information shall be provided to the Division within
fifteen (15) days after issuance of permit.
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III.E.)
5. 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
6. 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
El
004
2.16
---
3.71
Point
Truck Loadout
005
---
9.1
---
Point
AIRS ID: 123/9A7D/004-007
Page 2 of 19
Trado Department of Public Health and Environment
Air Pollution Control Division
00 e Z a -'
FUG
SS
006
---
7.12
---
Fugitive
Pnuematic
Pumps
007
---
4.78
2.44
Point
See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
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
a new twelve-month total shall be calculated based on the previous 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.
7. 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
El
004
Non -Selective Catalytic Reduction
NOx and CO
Pnuematic
Pumps
007
Enclosed Flare
VOC
8. Point 006: The operator shall calculate actual emissions from this emissions point based
on representative component counts for the facility with the most recent extended gas
analysis, 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.
PROCESS LIMITATIONS AND RECORDS
9. These sources 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
Point
Process Parameter
Annual
Limit
El
004
Consumption of natural gas as a fuel
6.3
MMscf/yr
Truck
Loadout
005
Condensate Loading
82,125
BBL/yr
AIRS ID: 123/9A7D/004-007
Page 3 of 19
Tado Department of Public Health and Environment
Air Pollution Control Division
a
Ventf j of natural gas used to drive two
10.6
rPn
Pumps
U07 1'
pneumatic pumps
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
10. Points 004,005,007: 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)
11. 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 Regulation 7,
Sections XII.C.1.d or XVI1.B.1.c shall have 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 005: 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)
14. This source is subject to Regulation No. 7, Section XII.C General Provisions (State only
enforceable). All condensate collection, storage, processing and handling operations,
regardless of size, shall be designed, operated and maintained so as to minimize
leakage of volatile organic compounds to the atmosphere to the maximum extent
practicable. The operator shall comply with all applicable requirements of Section XII.
15. Point 006: 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
AIRS ID: 123/9A7D/004-007 Page 4 of 19
rado Department of Public Health and Environment
Air Pollution Control Division
ged , x cordance 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.
Hi. 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 two 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
infeasible to make the repair within 15 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. Points 004, 007: 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 006: Within one hundred and eighty days (180) after issuance of this permit, the
owner or operator shall complete the initial extended gas analysis of gas samples that is
representative of volatile organic compound (VOC) and hazardous air pollutants (HAP)
that may be released as fugitive emissions. This extended gas analysis shall be used in
the compliance demonstration as required in the Emission Limits and Records section of
this permit. The operator shall submit the results of the gas analysis and emission
calculations to the Division as part of the self -certification process to ensure compliance
with emissions limits.
18. Point 006: Within one hundred and eighty days (180) after commencement of operation,
the operator shall complete 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
AIRS ID: 123/9A7D/004-007 Page 5 of 19
isi
limits.
ado Department of Public Health and Environment
Air Pollution Control Division
f-ce -tion process to ensure compliance with emissions
Periodic Testing Requirements
19. Point 004: This engine may be subject to the periodic testing requirements as specified
in the operating and maintenance (O&M) plan as approved by the Division. Revisions to
your O&M plan are subject to Division approval. Replacements of this unit completed as
Alternative Operating Scenarios may be subject to additional testing requirements as
specified in Attachment A.
20. Point 006: 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 analysis shall be used in the compliance demonstration as required in the
Emission Limits and Records section of this permit.
ALTERNATE OPERATING SCENARIOS
21. Point 007: These pumps 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.
22. Point 007: 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.
23. Point 007: 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
24. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, II.C)
a. Annually by April 30th whenever a significant increase in emissions occurs as
follows:
For any criteria pollutant:
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 (NOx) in
ozone nonattainment areas emitting less than 100 tons of VOC or NOx 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
AIRS ID: 123/9A7D/004-007 Page 6 of 19
ado Department of Public Health and Environment
Air Pollution Control Division
o flEhia re r . ble 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.
f. Within 14 calendar days of commencing operation of a permanent replacement
engine under the alternative operating scenario outlined in this permit as
Attachment A. The APEN shall include the specific manufacturer, model and
serial number and horsepower of the permanent replacement engine, the
appropriate APEN filing fee and a cover letter explaining that the owner or
operator is exercising an alternative -operating scenario and is installing a
permanent replacement engine.
25. 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).
26. MACT Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines requirements shall apply to this
source at any such time that this source becomes major solely by virtue of a relaxation in
any permit limitation and shall be subject to all appropriate applicable requirements of
that Subpart on the date as stated in the rule as published in the Federal Register.
(Reference: Regulation No. 8, Part E)
27. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil
and Natural Gas Production Facilities major stationary source requirements shall apply
to this stationary source at any such time that this stationary source becomes major
solely by virtue of a relaxation in any permit limitation and shall be subject to all
appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part
E)
GENERAL TERMS AND CONDITIONS:
28. 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.
29. 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
AIRS ID: 123/9A7D/004-007 Page 7 of 19
rado Department of Public Health and Environment
Air Pollution Control Division
ho►Ratidfl•ettheairttll�nusrtltsecured 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.
30. 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
construction, installation and operation of the source, in accordance 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.
31. 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.
32. 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.
33. 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.
34. 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:
Peter Armington
Permit Engineer
AIRS ID: 123/9A7D/004-007 Page 8 of 19
F rado Department of Public Health and Environment
Air Pollution Control Division
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Bonanza Creek Energy Operating
Company LLC
AIRS ID: 123/9A7D/004-007 Page 9 of 19
D
rado Department of Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder at the time of this permit issuance:
1) The production or raw material processing limits and 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.
2) 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/requlations/airregs/100102aacccommonprovisionsreq.pdf.
3) 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
AIRS
Point
Pollutant
CAS #
BIN
Uncontrolled
Emission
Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (lb/yr)
004
Formaldehyde
5000
A
139
Yes
139
Methanol
67561
C
18
No
18
Acetaldehyde
75070
A
16
No
16
Acrolein
107028
A
15
No
15
Benzene
71432
A
9
No
9
1,3 -Butadiene
106990
A
4
No
4
Toluene
108883
C
3
No
3
005
n -Hexane
110543
C
1260
Yes
1260
Benzene
71432
A
280
Yes
280
Toluene
108883
C
540
No
540
Ethylbenzene
100414
C
120
No
120
Xylenes
1330207
C
520
No
520
006
Benzene
71432
A
106
Yes
106
Toluene
108883
C
189
No
189
Ethylbenzene
100414
C
44
No
44
Xylenes
1330207
C
175
No
175
n -Hexane
110543
C
581
No
581
007
71432
Benzene
A
505
Yes
25
108883
Toluene
C
391
No
20
AIRS ID: 123/9A7D/004-007
Page 10 of 19
Trado Department of Public Health and Environment
Air Pollution Control Division
1330207
Xylenes
C
194
No
10
110543
n -Hexane
C
3927
Yes
196
100414
Ethylbenzen
C
27
No
1.3
4) The emission levels contained in this permit are based on the following emission factors:
Point 004:
CAS
Pollutant
Emission
Uncontrolled
Ib/MMBtu
Factors -
g/bhp-hr
Emission
Controlled
lb/MMBtu
Factors —
g/bhp-hr
NOx
3.9197
14.7000
0.7447
2.793
CO
1.5465
5.8000
1.2799
4.8000
VOC
0.0107
0.0400
0.0107
0.0400
5000
Formaldehyde
0.021
0.0900
0.021
0.0900
67561
Methanol
0.0031
0.0115
0.0031
0.0115
75070
Acetaldehyde
0.0028
0.0105
0.0028
0.0105
107028
Acrolein
0.0026
0.0099
0.0026
0.0099
71432
Benzene
0.0016
0.0059
0.0016
0.0059
106990
1,3 -Butadiene
0.0007
0.0025
0.0007
0.0025
108883
Toluene
0.0006
0.0021
0.0006
0.0021
Emission factors are based on a Brake-Specfic Fuel Consumption Factor of 8268 Btu/hp-hr, a
site -rated horsepower value of 80, and a fuel heat value of 918 Btu/scf.
Emission Factor Sources:
CAS
Pollutant
Uncontrolled EFSource
Controlled EF Source
NOx
Manufacturer Spec Sheet
Manufacturer Spec Sheet
CO
Manufacturer Spec Sheet
Manufacturer Spec Sheet
VOC
Manufacturer Spec Sheet
No Control
5000
Formaldehyde
AP -42; Table 3.2-3 (7/2000);
Natural Gas
No Control
67561
Methanol
AP -42; Table 3.2-3 (7/2000);
Natural Gas
No Control
75070
Acetaldehyde
AP -42; Table 3.2-3 (7/2000);
Natural Gas
No Control
107028
Acrolein
AP -42; Table 3.2-3 (7/2000);
Natural Gas
No Control
71432
Benzene
AP -42; Table 3.2-3 (7/2000);
Natural Gas
No Control
106990
1,3 -Butadiene
AP -42; Table 3.2-3 (7/2000);
Natural Gas
No Control
108883
Toluene
AP -42; Table 3.2-3 (7/2000);
Natural Gas
No Control
Point 005:
CAS
Pollutant
Emission Factors - Uncontrolled
lb/BBL loaded
Source
VOC
0.222
AP -42
110543
n -Hexane
0.015
AP -42
71432
Benzene
0.0033
AP -42
AIRS ID: 123/9A7D/004-007
Page 11 of 19
Tado Department of Public Health and Environment
Air Pollution Control Division
mar
CAS
a.a
Pollutant
Emission Factors - Uncontrolled
lb/BBL loaded
Source
108883
Toluene
0.0066
AP -42
100414
Ethylbenzene
0.0016
AP -42
1330207
Xylenes
0.0064
AP -42
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) = 10.16 psia
M (vapor molecular weight) = 36.41 lb/lb-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 liquids by the VOC emission factor.
Point 006:
Component
Gas Service
Heavy Oil
Light Oil
Water/Oil
Service
Connectors
893
334
245
Flanges
95
141
80
Open-ended Lines
47
22
5
Pump Seals
0
0
0
Valves
145
74
42
Other*
26
0
4
VOC Content (wt.
fraction)
0.2928
N/A
0.9971
1.0000
Benzene Content (wt.
fraction)
0.0008
N/A
0.0150
0.0001
Toluene Content (wt.
fraction)
0.0006
N/A
0.0298
0.0012
Ethylbenzene (wt.
fraction)
0.0001
N/A
0.0071
0.0003
Xylenes Content (wt.
fraction)
0.0003
N/A
0.0288
0.0001
n -hexane Content (wt.
fraction)
0.0060
N/A
0.0692
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
N/A
2.1E-04
1.1E-04
Flanges
3.9E-04
N/A
1.1E-04
2.9E-06
Open-ended Lines
2.0E-03
N/A
1.4E-03
2.5E-04
AIRS ID: 123/9A7D/004-007
Page 12 of 19
Trado Department of Public Health and Environment
Air Pollution Control Division
ump SeasE-03
NA
1.3E-02
2.4E-05
Valves
4.5E-03
N/A
2.5E-03
9.8E-05
Other
8.8E-03
N/A
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 007:
AIRS
Point
CAS #
Pollutant
Emission Factors
- Uncontrolled
Ib/MMscf vented
Emission Factors
- Controlled
Ib/MMscf vented
Source
007
VOC
18,034
902
All emission factors
are based on the
stated consumption
and the North Platte
44-11-28HZ gas
analysis dated
5/25/2012
NO,
0.0689 lb/MMBTU
CO
0.37 lb/MMBTU
108883
Toluene
37
1.8
1330207
Xylenes
18
0.92
110543
n -Hexane
373
19
71432
Benzene
48
2.4
The displacement equation can found in "EPA Emission Inventory Improvement Program Publication:
Volume II, Chapter 10 - Displacement Equation (10.4-3)."
Emission factors for CO and NOx found in AP -42 Table 13.5-1. A HHV of 1,255 BTU/scf was used
for calculations.
5) 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.
6) Point 003: This engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for
Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register
posting — effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality
Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA
website at: http://www.epa.qov/ttn/atw/area/fr18ia08.pdf
7) Point 003: This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards
for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines (See August 20,
2010 Federal Register posting - effective October 19, 2010). The August 20, 2010 amendments to
include requirements for existing engines located at area sources and existing engines < 500 hp
located at major sources have not yet been incorporated into Colorado Air Quality Control
Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at:
http://www.epa.gov/ttn/atw/rice/fr20au10.pdf Additional information regarding area source standards
can be found on the EPA website at: http://www.epa.qov/ttn/atw/area/arearules.html
8) This facility is classified as follows:
AIRS ID: 123/9A7D/004-007 Page 13 of 19
Trado Department of Public Health and Environment
Air Pollution Control Division
ear S
Applicable
Requirement
SS S
Status
Operating Permit
Synthetic Minor Source of: VOC
NANSR
Synthetic Minor Source of: VOC
MACT ZZZZ
Area Source Requirements: Applicable
MACT HH
Area Source Requirements: Not Applicable
NSPS KKK
Not Applicable
NSPS OOO0 ,
Not Applicable
9) 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 ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
10) An Oil and Gas Industry Construction 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/oilgaspermittinghtml
AIRS ID: 123/9A7D/004-007 Page 14 of 19
rado Department of Public Health and Environment
Air Pollution Control Division
A CHMENT A:
ALTERNATIVE OPERATING SCENARIOS
RECIPROCATING INTERNAL COMBUSTION ENGINES
October 12, 2012
2. Alternative Operating Scenarios
The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of
natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the
requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating
Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary
Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all
applicable substantive and procedural requirements. This permit incorporates and shall be considered a
Construction Permit for any engine replacement performed in accordance with this AOS, and the owner
or operator shall be allowed to perform such engine replacement without applying for a revision to this
permit or obtaining a new Construction Permit.
2.1 Engine Replacement
The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown
or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a
temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90
operating days or less in any 12 month period. "Permanent" is defined as in the same service for more
than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is
in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90
day total. The compliance demonstrations and any periodic monitoring required by this AOS are in
addition to any compliance demonstrations or periodic monitoring required by this permit.
All replacement engines are subject to all federally applicable and state -only requirements set forth in this
permit (including monitoring and record keeping).
The results of all tests and the associated calculations required by this AOS shall be submitted to the
Division within 30 calendar days of the test or within 60 days of the test if such testing is required to
demonstrate compliance with NSPS or MACT requirements.
Results of all tests shall be kept on site for five (5) years and made available to the Division upon request.
The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date
of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and
serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer,
model number, horsepower, and serial number of the replacement engine. In addition to the log, the
owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make
them available to the Division upon request.
2.1.1 The owner or operator may temporarily replace an existing compressor engine that is subject to
the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and
horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying
this permit, so long as the temporary replacement engine complies with all permit limitations and other
requirements applicable to the existing engine. Measurement of emissions from the temporary
replacement engine shall be made as set forth in section 2.2.
AIRS ID: 123/9A7D/004-007 Page 15 of 19
rado Department of Public Health and Environment
Air Pollution Control Division
2.1:°""o to rma °r ly replace the existing compressor engine with another
engine with the same manufacturer, model, and horsepower engines without modifying this permit so
long as the permanent replacement engine complies with all permit limitations and other requirements
applicable to the existing engine as well as any new applicable requirements for the replacement engine.
Measurement of emissions from the permanent replacement engine and compliance with the applicable
emission limitations shall be made as set forth in section 2.2.
An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial
number and horsepower of the permanent replacement engine shall be filed with the Division for the
permanent replacement engine within 14 calendar days of commencing operation of the replacement
engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that
the owner or operator is exercising an alternative operating scenario and is installing a permanent
replacement engine, and a copy of the relevant Applicability Reports for the replacement engine.
Example Applicability
Reports can be found at http://www.cdphe.state.co.us/ap/oilgaspermitting.html. This submittal shall be
accompanied by a certification from the Responsible Official indicating that "based on the information and
belief formed after reasonable inquiry, the statements and information included in the submittal are true,
accurate and complete".
This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine
or an engine that is not subject to emission limits.
The owner or operator shall agree to pay fees based on the normal permit processing rate for review of
information submitted to the Division in regard to any permanent engine replacement.
2.2 Portable Analyzer Testing
Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping
Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss
streamlining the testing requirements.
Note that the testing required by this Condition may be used to satisfy the periodic testing requirements
specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer
testing, this test conducted under the AOS will serve as the quarterly test and an additional portable
analyzer test is not required for another three months).
The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required
by this Condition, if approved in advance by the Division.
The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the
exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of
commencing operation of the replacement engine.
All portable analyzer testing required by this permit shall be conducted using the Division's Portable
Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at:
http://www. colorado.gov/cs/Satellite/CD P H E-AP/CBON/1251596520270.
Results of the portable analyzer tests shall be used to monitor the compliance status of this unit.
For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the
tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or
year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation
the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever
applies.
AIRS ID: 123/9A7D/004-007 Page 16 of 19
ado Department of Public Health and Environment
Air Pollution Control Division
For . .=ris t ort it th-- °either input based (lb/mmBtu), output based (g/hp-hr) or
concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement
engine will be subject to, the results of the test shall be converted to the appropriate units as described in
the above -mentioned Portable Analyzer Monitoring Protocol document.
If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the
absence of credible evidence to the contrary, the source may certify that the engine is in compliance with
both the NOX and CO emission limitations for the relevant time period.
Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if
the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission
limitations, the engine will be considered to be out of compliance from the date of the portable analyzer
test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or
until the engine is taken offline.
2.3 Applicable Regulations for Permanent Engine Replacements
2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2
All permanent replacement engines that are located in an area that is classified as
attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT)
for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and
NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which
the area is in attainment/maintenance or nonattainment, except as follows:
In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of
emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds
40 tons/yr.
For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating
internal combustion engines:
VOC: The emission limitations in NSPS JJJJ
CO: The emission limitations in NSPS JJJJ
NOX: The emission limitations in NSPS JJJJ
SO2: Use of natural gas as fuel
PM10: Use of natural gas as fuel
As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains
20.0 grains or less of total sulfur per 100 standard cubic feet.
2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State -
Only conditions).
Control Requirements: Section XVI
Any permanent replacement engine located within the boundaries of an ozone nonattainment area is
subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified
below:
Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non-
selective catalyst and air fuel controller to reduce emission.
Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation
catalyst to reduce emissions.
AIRS ID: 123/9A7D/004-007 Page 17 of 19
ado Department of Public Health and Environment
Air Pollution Control Division
The above emission control equipment shall be appropriately sized for the engine and shall be operated
and maintained according to manufacturer specifications.
The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2.
Emission Standards: Section XV/l.E — State -only requirements
Any permanent engine that is either constructed or relocated to the state of Colorado from another state,
after the date listed in the table below shall operate and maintain each engine according to the
manufacturer's written instructions or procedures to the extent practicable and consistent with
technological limitations and good engineering and maintenance practices over the entire life of the
engine so that it achieves the emission standards required in the table below:
Max Engine HP
Construction or
Relocation Date
Emission Standards in G/hp-hr
NOx
CO
VOC
January 1, 2008
2.0
4.0
1.0
100<Hp<500
January 1, 2011
1.0
2.0
0.7
500<Hp
July 1, 2007
July 1, 2010
2.0
1.0
4.0
2.0
1.0
0.7
The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2.
2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ
A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater
than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp
except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for
lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements
of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting
requirements for the permanent engine replacement shall be included in the Applicability Reports
required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this
AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this
AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted
within the time frame specified in Condition 2.2.
Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from
outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to
the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes
equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ
requirements).
However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does,
any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ,
there will be an additional step added to the determination of the NSPS. Under the provisions of
Regulation No. 6, Part 8, § 1.8 (which is referenced in Part A), any engine relocated from outside of the
State of Colorado into the State of Colorado is considered to be a new source, subject to the
requirements of NSPS JJJJ.
2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ
A permanent replacement engine located at either an area or major source is subject to the requirements
in 40 CFR Part 63, Subpart 7777 An analysis of the applicable monitoring, recordkeeping, and reporting
AIRS ID: 123/9A7D/004-007 Page 18 of 19
rado Department of Public Health and Environment
Air Pollution Control Division
regs th m- •ineflacement shall be included in the Applicability Reports
required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this
AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under
Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time
frame specified in Condition 2.2.
2.4 Additional Sources
The replacement of an existing engine with a new engine is viewed by the Division as the installation of a
new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an
advanced construction permit review. The AOS cannot be used for additional new emission points for any
site; an engine that is being installed as an entirely new emission point and not as part of an AOS-
approved replacement of an existing onsite engine has to go through the appropriate
Construction/Operating permitting process prior to installation.
AIRS ID: 123/9A7D/004-007 Page 19 of 19
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Bonanza Creek Energy Operating Company LLC
Permit Number:
12WE3095
Source Name:
Latham14-2 Production Pad
Source Location:
SWSW Sec 2 T4N R63W
Equipment Description:
Loadout for loading condensate and produced water into trucks,
Fugitives
AIRS ID:
12319A53/005-006
Review Date:
3/5/2013
Review Engineer:
Peter Armington
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?
November 13, 2012
Section 4 —Source Description
AIRS Point
Equipment Description
005
Truck Condensate Loadout
006
Fugitives
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,o
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 1
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
005
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]
006
EPA -453/R-95-017, Table 2-4
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
005
82,125 BBL per year condensate loaded
006
Equipment Type
Gas
Heavy Oil (or
Heavy Liquid)
Light Oil (or
Light Liquid)
Water/Oil
Connectors
893
334
245
Flanges
95
141
80
Open -Ended Lines
47
22
5
Pump Seals
0
0
0
Valves
145
74
42
Other
26
0
4
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
005
82,125 BBL per year condensate loaded
006
Equipment Type
Gas
Heavy Oil (or
Heavy Liquid)
Light Oil (or
Light Liquid)
Water/Oil
Connectors
893
334
245
Flanges
95
141
80
Open -Ended Lines
47
22
5
Pump Seals
0
0
0
Valves
145
74
42
Other
26
0
4 _
Does this source use a control device?
Yes
X
No
Section 6 — Emission S (t per year)
Summa (tons
Point NO„
VOC
CO
Single HAP
HAP
Page 2
•
PTE:
005
9.1
0.63 (n -hexane)
1.36
006
7.12
0.27 (Hexane)
0.52
Total
16.2
0.90 (n -Hexane)
1.88
Uncontrolled point
source emission rate:
005
9.1
0.63 (n -hexane)
1.36
006
7.12
0.27 (Hexane)
0.52
Total
16.2
0.90 (n -Hexane)
1.88
Permitted point source
emission rate:
005
9.1
0.63 (n -hexane)
1.36
006 '
7.12
0.27 (Hexane)
0.52
Total
16.2
0.90 (n -Hexane)
1.88
Section 7 — Non -Criteria / Hazardous Air Pollutants
Point
Pollutant
CAS #
BIN
Uncontrolled
Emission
Rate
(Iblyr)
Are the
emissions
reportable
Controlled Emission
Rate (Ibryr)
005
Benzene
71432
A
280
Yes
N/A
n -Hexane
110543
C
1260
Yes
N/A
Toluene
108883
C
540
No
N/A
Ethylbenzene
100414
C
120
No
N/A
Xylenes
1130207
C
520
No
N/A
006
Benzene
71432
A
106
Yes
N/A
Toluene
108883
C
189
No
N/A
Ethylbenzene
100414
C
44
No
N/A
Xylenes
1330207
C
175
No
N/A
n -Hexane
110543
C
581
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
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? X Yes
No
Page 3
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
005,006
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
005,006
Section I.A - 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.
Regulation 3 - APENs, Construction Permits, Operating Permits, PSD
005,006
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for:
each individual emission point in a nonattainment area with uncontrolled actual emissions
of one tons per year or more of any individual criteria pollutant (pollutants are not summed)
for which the area is nonattainment.
(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 Il.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 located in the 8 -hour ozone
nonattainment area, but not the 1 -hour ozone area.
Point 005: 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.
Point 006: Source is using the division standard DI&M plan to comply with RACT, with
semi-annual AVO screenings.
Regulation 6 - New Source Performance Standards
005,006
No applicable subpart. This facility is not a bulk gasoline terminal.
Regulation 7 — Volatile Organic Compounds
005,006
No sections apply. This facility is neither a terminal, nor a bulk plant per definitions in Reg
7, Section VI.C.
Regulation 8 — Hazardous Air Pollutants
005,006
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
(%)
Page 4
005
01
Truck Condensate
Loadout
82,125
BBL/yr
5.28
lb/1,000
gallon
throughput
VOC
No
AP -42
0
01
Truck Condensate
Loadout
82,125
BBL/yr
0.0791
lb/1,000
gallon
throughput
Benzene
No
AP -42
0
01
Truck Condensate
Loadout
82,125
BBL/yr
0.365
lb/1,000
gallon
throughput
n -Hexane
No
AP -42
0
SCC
40600132: Crude Oil: Submerged Loading (Normal Service)
006
01
Fugitive VOC
Leak Emissions
___
___
VOC
Yes
EPA -453/R-95-
017, Table 2-4
0
SCC
31000220: All Equip. Leak Fugitives (Valves, flanges, connections, seals, drains)
Section 14 — Miscellaneous Application Notes
AIRS Point
005
Truck Condensate Loadout
Units
Basis
S
0.6
Submerged loading:
dedicated normal service
based on source's
description/drawings
P
10.16
Psia
AP -42 Figure 7.1-13a
M
36.41
Lb/lb-mole
E&P Tanks
T
524
Deg R
Based on source's
knowledge of bulk liquid
temperature
L
5.28
Lb/10^3 gal
0.222
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 5.281b/10^3 gal
0.2221b/bbl
Annual requested Throughput 3449250ga1/yr
Annual requested VOC emissions 182121b/yr
9.1 tpy
Page 5
Summary of Preliminary Analysis
- NG RICE
Company Name
Facility Name
Facility Location
Facility Equipment ID
Bonanza Creek Energy Operating Company LLC
Latham 14-2 Production Pad
SWSW Sec 2 T4N R63W
El
Permit No.
AIRS
Review Date
Permit Engineer
12WE3095
123/9A7D/004
03/05/2013
Peter Armington
Requested Action
Issuance No.
New permit/newly reported emission
1
Emission Point Description
One (1) Arrow, Model A-62, Serial Number To Be Determined, natural gas -fired, naturally aspirated, 4SRB reciprocating
internal combustion engine, site rated at 80 horsepower at 1800 RPM. This engine shall be equipped with a non -selective
catalytic reduction (NSCR) system. This emission unit powers a pump jack.
Natural Gas Consumption
Requested (mmscf/yr)
6.31
Requested (mmscf/m)
0.54
Fuel Heat Value (btu/scf)
918
BSCF (Btu/hp-hr)
8268
Emission Factor Sources
Uncontrolled
Controlled
NOx
Manufacturer
Manufacturer
VOC
Manufacturer
0
CO
Manufacturer
Manufacturer
Formaldehyde
Manufacturer
0
SOx
AP -42; Table 3.2-3 (7/2000), Natural Gas
No Control
TSP
AP -42; Table 3.2-3 (7/2000); Natural Gas
No Control
PM10
AP -42; Table 3.2-3 (7/2000); Natural Gas
No Control
PM2.5
AP -42, Table 3.2-3 (7/2000), Natural Gas
No Control
Other Pollutants
Point Summary of Criteria Emissions (t
Uncontrolled
Requested
Controlled
Requested
PTE
Proposed Control
Efficiency
NOx
11.4
2.2
11.4
81.0%
VOC
0.0
0.0
0.0
0.0%
CO
4.5
3.7
4.5
17.2%
SOx
0.0
0.0
0.0
0.0%
TSP
0.1
0.1
0.1
0.0%
PM10
0.1
0.1
0.1
0.0%
PM2.5
0.1
0.1
0.1
0.0%
Total HAPs'
0.0
0.0
0.1
0.0%
'Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de
minimus thresholds. PTE includes all HAPs calculated, even those below de minimus.
Point Summary of Hazardous Air Pollutants lb/yr
HAP Name
Uncontrolled
Requested
Controlled
Requested
PTE
Proposed Control
Efficiency
Formaldehyde
139
139
139
0.0%
Methanol
18
0.0%
Acetaldehyde
16
0.0%
Acrolein
15
0.0%
Benzene
9
0.0%
1,3 -Butadiene
4
0.0%
Toluene
3
0.0%
`Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED
UNCONTROLLED is greater than de minimus
Permitting Requirements
Ambient Air Impacts
Source is not required to model based on Division Guidelines
Public Comment
Public Comment Required
MACT 777Z
New/Recon 4SRB less than or equal to 500 HP located at a(n) Area Source
Reg 7 XVII.E
Standards (g/hp-hr)
NOx: NA CO: NA VOC: NA
Reg 7 XVI.B (Ozone NM
requirements) applies?
No
MACT ZZZZ (area source)
Is this engine subject to MACT ZZZZ area
source requirements?
Yes
NSPS JJJJ
Is this engine subject to NSPS JJJJ?
Yes
Note: JJJJ requriements are not currently included as permit conditions because the reg has not
been adopted into Reg 6.
Comments/Notes
0
GP02 Info:
This facility is a
Synthetic Minor
source for Title V, NSR, and/or MACT applicability.
This facility is a
True Minor
source of NOX and/or CO for Title V.
True Minor
source of formaldehyde for Title V.
No stack testing required.
Division Information
Engineer:
Peter Armngton
Control Engineer:
NA
Review Date:
03/05/2013
Application Date:
11/13/2012
Facility Identifiers
Permit No.
12WE3095
AIRS
County P
123 Weld
Facility P
9A7D
Point P
007
Facility Equipment ID
Pnuematic Pumps
Section 01: Administrative Information
Company Name:
Bonanza Creek Energy Operating Company LLC
Source Name:
Latham 14-2 Production Pad
Source Location:
SWSW Sec 2 T4N R63W
SIC:
1311
Elevation (feet)
4539
Mailing
Address
Address 1:
Address 2:
City, State Zip:
Bonanza Creek Energy Operating Company LLC
410 17th Street Suite 1500
Denver. CO
Person To
Contact
Name:
Phone:
Fax:
Email:
Kerry A. MCCowen
720-440-6108
720-279-2331
KAM ABonanzaCrkcom
Potentially Located within EAC - determine attainment status of NOx and VOC
Attainment Status
PM10
Attainment
PM2.5
Attainment
SOx
Attainment
NOx
Nonattainment
VOC
Nonattainment
CO
Anainment
Section 02: Requested Action
S
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
Request to limit HAPs with federally enforceable limits
Issuance Number 1
Addi Info
and notes:
Section 03: General Facility Information
For existing sources, opera ion began on: 8114/2012
For New/recon sources, projected startup date:
Normal hours of operation:
24 hrs/day
7 days/wk
13 weeks/yr
General description of equipment
purpose:
Heat trace urculabon and pi 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
45
gallons per minute pumped
Max. pump naturaI
gas consumption
600
scf/hour used
Section 05 Emission Calculations
Emeaan Calc alnn Melwc
EPA Emission Inventory improvement Program Publication: Volume s, Chapter 10 - Displacement Equation 110.4-31
Ex=0•MW'xx/C
Ex = emissions of pollutant x
O = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas • MW of air
xx = mass fraction of a in gas
C. molar volume of ideal gas (379 scf/Ib-mol) at 60F and 1 atm
D
1200
scf/hr
MW
215
lb/Ib-tool
Hauls al Op
8780
hoursyr
Requested Throughput
10.6 MMscf/yr
Component
mole %
MW
mass fraction
Component
lb/hr
lb/yr
tpy
propane
76307
44.09
0.1432
propane
10.652
93314.820
46.657
isobutane
0893
58.12
0.O221
isobutane
1.643
14395.382
7.198
n -butane
25968
58.12
0.0642
n -butane
4.779
41862.675
20.931
isopentane
0517
72.15
0.O1591sopentane
1.181
10346.013
5.173
n -pentane
06557
72.15
0.0201
n -pentane
1.498
13121.626
6.561
n -hexane
01543
86.18
0.0060
n -hexane
0.448
3927.265
1.964
cyclohexane
034'5
84.18
0.0015
cyclohexane
0.111
968.954
0.484
Other hexane
0 2532
86.18
0.0092
Other hexanea
0688
6028.340
3.014
heptanes
0.0024
100.21
0.0039
heptanes
0.293
2568.202
1.284
metbylcycloh
0028
98.19
0.0012
methylcycloho
0.087
762.555
0.381
224 -IMP
00001
114.22
0.0000
224-TMP
0.000
3.168
0.002
Benzene
00233
78.11
0.0008
Benzene
0.058
504.788
0.252
Toluene
0019
92.14
0.0006
Toluene
0.045
391.008
0.196
Ethylbenzene
O0009
106.17
0.0000
Ethylbenzene
0.003
26.503
0.013
Xylenes
00056
106.17
0.0003
Xylenes
0.022
194.353
0.097
Cea Heavies
00621
315
0.0083
CB' Heavies
0619
5425.607
2.713
Mass raction VOC: 0.2974
Total 96.921
Total
96.921 tpy VDC
Natea
Mode % MW asel pass rracl.onz lr0.. extended has enarysn tram Nola Pave 44-11-20dz gas anaiy s dared 52572012
CAS.
Total llb/yrl
Bin
Scenario A
Reportable?
mhexane
110843
3927.3
C
yes
224 -IMP
540841
3.2
C
No
Benzene
71432
504.8
A
yes
Toluene
108883
391.0
C
No
E-aeiuene
100414
26.5
c
No
Xylenes
1330207
1944
C
No
Rsaaoanl Fnsason Fa/t015
VOC 18439.998
Benzene 48.020
n -hexane 373.598
Toluene 37.196
E eenzene 2.521
Xylenes 18.489
224-TMP 0.301
/MMscf natural gas used
/MMscf natural gas used
/MMscf natural gas used
/MMscf natural gas used
/MMscf natural gas used
/MMscf natural gas used
/MMscf natural gas used
;
d ,
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[Provide Facility Equipment ID to identify how this equipment is referenced within your organization.]
Pnuematic Pum
O
nested Action (check applicable request boxes)
Section 02 — Re
C
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Latham 14-2 Production Pad
Source Name:
U
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Transfer of ownership
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Request to limit IIAPs with a Federally enforceable limit on PTE
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ZIP Code: 80202
410 17th Street, Suit 1500
Mailing Address
Denver, CO
re
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720-279-2331
(iijBonanzaCrk. corn
E-mail Address:
Section 03 — General Information
E
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FORM APCD-200
AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Pe
Emission Source AIRS ID:
Permit Number:
w
Section 05 — Emission Release Information (Attach a separate sheet with relevant information in the event of multiple releases; provide datum & either Lat/Long or UTM)
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Direction of outlet (check one):
Exhaust Opening Shape & Size (check one):
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Section 06 — Combustion E
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Manufacturer:
Company equipment Identification No.:
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Section 07 — Emissions Inventory Information & Emission Control Information
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Requested Permitted
Emissions4
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(Tons/Year)
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Controlled Actual
Emissions (lbs/year)
t0
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Uncontrolled Actual
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N-
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Emission
Factor Source
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Emission Factor
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0.448 lb/hr
0.448 lb/hr
Control Equipment /
Reduction (%)
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Reporting
BIN
0
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Chemical Name
n -Hexane
Benzene
Chemical
Abstract Service
(CAS) Number
110543
71432
Calendar Year for which Actual Data Applies:
cen
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