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Home My WebLink About20203840.tiffCOLORADO Department of public Health b Environment Weld County - Clerk to the Board 1150OSt PO Box 758 Greeley, CO 80632 December 16, 2020 Dear Sir or Madam: RECEIVED DEC 21 2020 WELD COUNTY COMMISSIONERS On December 17, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for Bonanza Creek Energy Operating Company, LLC - North Platte A-33 Production Facility. 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 beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.cotorado.gov/cdphe Jared Polis, Governor I Jilt Hunsaker Ryan, MPH, Executive Director Pub I ; C Rev; e c,J OI/o6/.2j Gc:Pt-CTP) HL.(05/-ra) PWCsM1ER/c1.1 oG 01.1.) 12/2.9 A0 2020-3840 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Bonanza Creek Energy Operating Company, LLC - North Platte A-33 Production Facility - Weld County Notice Period Begins: December 17, 2020 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: North Platte A-33 Production Facility Well Production Facility NWNW Section 33 T5N R63W Weld County The proposed project or activity is as follows: The applicant proposes a lowering of throughput and emission limits for tow pressure gas flaring, condensate tanks, and hydrocarbon loadout based on 2019 actual throughput and current approved emission factors and the use of state emission factors for hydrocarbon loadout. 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): • 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 15WE0418 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 https://www.colorado.gov/pacific/cdphe/air-permit-public-notices 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. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Joshua Jones Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 ICOLORADO Department of Public Health 6 Environment COLORADO Air Pollution Control Division Department of Public Health Fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 15WE0418 Issuance: 4 Bonanza Creek Energy Operating Company, LLC Facility Name: Plant AIRS ID: Physical Location: County: Description: North Platte A-33 Production Facility 123/9D43 NWNW Section 33 T5N R63W Weld County Well Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment Description Emissions Control Description LPGFL 007 ' Six (6) low pressure separators and One (1) Vapor Recovery Tower (VRT) vented during gas compressor downtime. Six (6) enclosed combustors with a minimum VOC control efficiency of 95% PWT-01 010 Two (2) 750 barrel produced water storage vessels. CNDTK-01 011 Eight (8) 800 barrel atmospheric condensate storage vessels. L-01 012 Hydrocarbon loadout to tanker trucks. 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 this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self -certify. (Regulation Number 3, Part B, Section III.G.5.) EMISSION LIMITATIONS AND RECORDS 2. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Page 1 of 14 COLORADO Air Pollution Control Division partment of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Annual Limits: N Equipment ID AIRS Point Tons per Year Emission Type NO, V0C CO LPGFL 007 1.2 27.8 5.2 Point PWT-01 010 --- 0.2 --- Point CNDTK-01 011 --- 6.4 --- Point L-01 ntn• Coe «AID+.., 4.. n-.....:� 012 LJ�IJ_.." --- L__ _-c__.__ _ 0.3 --- - Point Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must 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 must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 3. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 4. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment ID AIRS Point Control Device Pollutants Controlled LPGFL 007 Six (6) enclosed combustors VOC and HAP PWT-01 010 Six (6) enclosed combustors VOC and HAP CNDTK-01 011 Six (6) enclosed combustors VOC and HAP Page 2 of 14 COLORADO Air Pollution Control Division Department of Publtc Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado L-01 012 Six (6) enclosed combustors, VOC and HAP PROCESS LIMITATIONS AND RECORDS 5. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Equipment ID AIRS Point Process Parameter Annual Limit LPGFL 007 Gas vented from low pressure separators 14.75 MMscf PWT-01 010 Produced Water Throughput 34,954 barrels CNDTK-01 011 Condensate Throughput 46,030 barrels' L-01 012 Condensate Loaded 46,030 barrels Compliance with the annual throughput limits must 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 must, calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 6. Point 007: The owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The flow meter must be calibrated and maintained per the manufacturer's specifications and schedule. The flow meter must continuously measure flow rate and record total volumetric flow vented from each separator. The owner or operator must use monthly throughput records along with the methodology in the Operating and Maintenance Plan for these units to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 7. Points 007, 010, 011, and 012: The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 8. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) Page 3 of 14 COLORADO Air Pollution Control Division Department of Public Health 6 Enwonment Dedicated to protecting and improving the health and environment of the people of Colorado 9. Points 010 and 011: The storage tanks covered by this permit are subject to Regulation Number 7, Part D, Section I. The operator must comply with all applicable requirements of Section I and, specifically, must: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Part D, Section I.C.) 10. Points 007, 010, 011, and 012: The combustion devices covered by this permit are subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a combustion device is used to control emissions of volatile organic compounds and other hydrocarbons to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as definedunder Regulation Number 7, Part D, Section'II.A.24; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other, convenient means approved by the Division, determine whether it is operating` properly. This combustion device must be equipped with an operational auto -igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. (State only enforceable) 11. Points 010 and 011: The storage tanks covered by this permit are subject to the emission control requirements in Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have`a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to March 1, 2020. The source must follow the inspection requirements of Regulation Number 7, Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. (State only enforceable) 12. Points 010 and 011: The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2. The owner/operator shall maintain records in accordance with Regulation No. 7, Part D, Section II.C.3. and make them available to the Division upon request. The owner or operator shall maintain records of STEM, including the plan, any updates, and the certification, for the life of the storage tank. The owner/operator will maintain records of all required inspections and monitoring for a period of two years. (State only enforceable) 13. Point 012: Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by using (a) submerge fill and (b) a vapor collection and return system and/or air pollution control equipment. Compliance with Section II.C.5. must be achieved in accordance Page 4 of 14 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado with the following schedule: (Regulation Number 7, Part D, Section II.C.5.a.) (State only enforceable) • Facilities constructed or modified on or after May 1, 2020, must be in compliance by commencement of operation. • Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021. • Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.5.a.(i)(B) that exceed the hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal to 5,000 barrels per year on a rolling 12 -month basis must control emissions from loadout upon exceeding the loadout threshold. 14. Point 012: Storage tanks must operate without venting at all times during loadout. (Regulation Number 7, Part D, Section II.C.5.a.(ii)) (State only enforceable) 15. Point 012: The owner or operator must, as applicable (Regulation Number 7, Part D, Section II.C.5.a.(iii)) (State only enforceable): Install and operate the vapor collection and return equipment to collect vapors during the loadout of hydrocarbon liquids to tank compartments of outbound transport vehicles and to route the "vapors to the storage tank or air pollution control equipment. Include devices to prevent the release of vapor from vapor recovery hoses not in use. Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to transport vehicles unless the vapor collection and return system is in use. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. • The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loadout. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring. 16. Point 012: The owner or operator must perform the following observations and training (Regulation Number 7, Part D, Section II.C.5.a.(iv)) (State only enforceable): • The owner or operator must observe loadout to confirm that all storage tanks operate without venting when loadout operations are active. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring, • If observation of loadout is not feasible, the owner or operator must document the annual loadout frequency and the reason why observation is not feasible and inspect the facility within 24 hours after loadout to confirm that all storage tank thief hatches (or other access point to the tank) are closed and latched. Page 5 of 14 COLORADO Au Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado • The owner or operator must install signage at or near the loadout control system that indicates which loadout control method(s) is used and the appropriate and necessary operating procedures for that system. • The owner or operator must develop and implement an annual training program for employees and/or third parties conducting loadout activities subject to Section II.C.5. that includes, at a minimum, operating procedures for each type of loadout control system. 17. Point 012: The owner or operator must retain the records required by Regulation Number 7, Part D, Section II.C.5.a.(v) for at least two (2) years and make such records available to the Division upon request. (State only enforceable) • Records of the annual facility hydrocarbon liquids loadout to transport vehicles throughput. Inspections, including a description of any problems found and their resolution, required under Sections IL.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log. Records of the infeasibility of observation of loadout. Records of the frequency of loadout. Records of the annual training program, including the date andnamesof persons trained. 18. Point 012: Air pollutioncontrol equipment used to comply with this Section II.C.5. must comply with Section II.B., be inspected in accordance with Sections II.C.1.d.(ii) through (v), and achieve a`hydrocarbon control efficiency of 95%. (Regulation Number 7, Part D, Section II.C.5.a.(vi)) (State only enforceable) 19. Point 007: The separators covered by this permit are subject to Regulation 7, Part D, Section II.F. On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the commencement of operation by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. 20. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division -approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) (State only enforceable) Page 6 of 14 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado OPERATING Et MAINTENANCE REQUIREMENTS 21. Points 007, 010, 011, and 012: Upon startup of these points, the owner or operator must 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 the atM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Periodic Testing Requirements 22. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 23. All previous versions of this permit are cancelled upon issuance of this permit. 24. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) Annually by April 30t 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 (NO.) 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. • Whenever there is a change in the owner or operator of any facility, process, or activity; or Page 7 of 14 COLORADO Air Pollution Control Division Department of Public Health b En tronment Dedicated to protecting and improving the health and environment of the people of Colorado • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 25. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Equipment ID AIRS Point Equipment Description Pollutant Emissions - tons per year Threshold Current Permit Limit LPGFL 007 Separator Venting NOx VOC 50, 50 1.2 34.7 PWT-01 010 Produced Water Storage Vessels CNDTK-01 011 Condensate Storage Vessels L-01 012 Hydrocarbon Loadout __ Insignificant Sources Note: APEN and permit exempt sources do not have permit limits. However, the PTE of these sources (excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR. GENERAL TERMS AND CONDITIONS 26. 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 Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 27. 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 Page 8 of 14 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 Number 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. 28. 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. 29. 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. 30. 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 must constitute a rejection of the entire permit and upon such occurrence, this ,permit must be deemed deniedab 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 of a source may request a hearing before the AQCC for review of the Division's action. 31. 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. 32. 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: Joshua Jones Permit Engineer Page 9 of 14 COLORADO Air Pollution Control Division Departrnent of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit History Issuance Date Description Issuance 4 This Issuance Issued to Bonanza Creek Energy Operating Company. Modification to points 007, 011 and 012 to reduce throughput and emission limits. Revise point 012 for use of state approved emission factors. Issuance 3 February 15, 2017 Issued to Bonanza Creek Energy Operating Company for modification to point 011 to account for increased emissions. Issuance 2 July 13, 2016 Issued to Bonanza Creek Energy Operating Company -Modification to Point 007, 01O, 011, and 012 -Cancellation of Point 006 Issuance 1 October 8, 2015 Issued to Bonanza Creek Energy Operating Company Page 10 of 14 COLORADO Air Pollution Control Division Department of Public Health El Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 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 must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI. B. ) 2) 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. 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 must 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: https://www.colorado.gov/pacific/cdphe/agcc-regs 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 Divisions analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) LPGFL 007 Benzene 71432 2502 125 Toluene 108883 2090 105 Ethylbenzene 100414 114 6 Xylenes 1330207 669 33 n -Hexane 110543 19,555 978 2,2,4- Trimethylpentane 540841 1079 54 PWT-01 010 Benzene 71432 245 12 n -Hexane 110543 769 38 CNDTK-01 011 Benzene 71432 1,335 67 Toluene 108883 1,616 81 Ethylbenzene 100414 92 5 Xylenes 1330207 612 31 n -Hexane 110543 11,015 551 2,2,4- Trimethylpentane 540841 732 37 L-01 012 Benzene 71432 19 1 n -Hexane 110543 166 8 Page 11 of 14 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 007 (LPGFL): CAS # Pollutant Uncontrolled Emission Factors (lb/MMscf) Controlled Emission Factors (lb/MMscf) Source N0x --- 154.50 AP -42 Table 13.5-1 CO --- 704.32 AP -42 Table 13.5-2 V0C 75, 324.65 3766.23 Site -Specific Gas Analysis and ProMax 71432 Benzene ' 169.6 8.48 108883 Toluene ` 141.6 7.08 100414 Ethylbenzene 7.71 0.39 1330207 Xylene 45.33 2.27 110543 n -Hexane: 1,325.77 66.29 540841 2,2,4 Trlmethylpentane 73.13 3.66 tote: The controlled emissions factors for this point are based on a control efficiency of 95%. NOX and CO lb/MMscf values calculated based on a HHV of 2272 Btu/scf (from weighted average of separator analysis and VRT ProMax results) and emission factors from AP -42 (NOX - 0.068 lb/MMBtu CO - 0.31 lb/MMBtu). Point 010 (PWT-01): CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source V0C 0.262 0.013 CDPHE 71432 Benzene 0.007 0.0004 CDPHE 110543 n -Hexane 0.022 0.001 CDPHE ote: The controlled emissions factors for this point are based on a control efficiency of 95%. Point 011 (CNDTK-01): CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source V0C 5.5288 0.2764 ProMax 71432 Benzene 0.0290 0.0015 ProMax 108883 Toluene 0.0351 0.0018 ProMax 100414 Ethylbenzene 0.0020 0.0001 ProMax 1330207 Xylene 0.0133 0.0007 ProMax Page 12 of 14 atu, COLORADO Air Pollution Control Division Department of Public Health b Ennronment Dedicated to protecting and improving the health and environment of the people of Colorado CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source 110543 n -Hexane 0.2393 0.0120 ProMax 540841 2'2'4- Tnmethylpentane 0.0159 0.0008 ProMax Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Point 012 (L-011: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 0.236 0.012 CDPHE Benzene 71432 0.00041 2.1e-5 CDPHE n -Hexane '110543 0.0036 1.8e-4 CDPHE Note: The controlled emissions factors for this point are based on a control efficiency o 95% and a collection efficiency of 100% 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 must 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, HAP PSD True Minor Source of: CO, NOx, VOC NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories Page 13 of 14 COLORADO Air Pollution Control Division Department of Pubdc Health Er Enwronment Dedicated to protecting and improving the health and environment of the people of Colorado 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 Page 14 of 14 jest PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: For Division Use Only 232266 s,W2p40 " 11/3/2020 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: .Ex~#ora*. crr Fei7ductlo^ fel3 P What industry segment?-Cil c-NetEatal Gas PrcciuClnriA Frn Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? Weld County Section 02 - Emissions Units In Permit Application Emissions Control? Quadrant Section Township Range Leave Blank - For Division Use Only AIRS Point # (Leave blank unless APCD has already assigned) Emissions Source Type Equipment Name Permit # (Leave blank unless APCD has already assigned) Issuance Self Cert Required? Action Engineering Remarks Separator Venting LPGR. 1ST _#'£0-418 Permit fJodifica;icm Yes 012 Laquid Eoadl a bC 1 yes _1ST kre0428 " .. Permit Mods .catim Section 03 - Description of Project Reques cures -)112C em s err nd state owe€ tnroughput and e^,>s¢o Ismits Requesting lower throughput and,'J0 Cars from: current CP. Requesting'osv ow pressure gas faring l �� L; point Cat 7teased on 2019 actual throughput end e mts_rod taCtorSfrom -sleds ;,mil for condensate tanks (CraDT t)c0_, point 031: ,1 area on actual can tenSate thrOsighOut oe 20 ghnut and 'V0c emiasion l:intts floe ecrndensate lOadout (10-1, Obint 0.1.2) based on actual 2v t9 tnepiOth Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? ,iyi". _Y,=_s- Ifyes,why? rc_questing5 rsthwtichtrr Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? Na Ifyes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? he Is this stationary source synthetic minor? Yc If yes, indicate programs and which pollutants: SO2 NOx CO VOC Prevention of Significant Deterioration (PSD) El E3 D E3 Title V Operating Permits (OP) E3 El D ✓ Non -Attainment New Source Review (NANSR) PM2.5 O O PM10 TSP ❑ E3 ® HAPs r-;1 O Colorado Air Permitting Project is this stationary source a major source? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs El O Separaten Venting Emissions inventory Section 01- Administrative Information Facility AIRS ID: 123 County 9043 Plant 007 Point Section 02- Equipment Desorption Details prz�Sux nd One (1) Vapor Reco Emission Control Device Description: -Emissions are can4relied by sin (b) enclosed crimbustors (ECD 01-u5) during gas compressor downtime. The enclosed cohave a Requested Overall VOC & HAP Control Efficiency %: 5 Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = IRequested Permit Limit Throughput 75 MMscf per year Potential to Emit (PTE) Throughput = 15..15. MMscf per year Requested Monthly Throughput= MMsd per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL o liquids throughput: 2272.01: Btu/scf scf/bbl Control Device Pilot Fuel Use Rate: Pilot Fuel Gas Heating Value: scfh Btu/scf fi 0 MMsd/yr Section 04 - Emissions Factors & Methodologies Description The lour pressure separators receive liquids from the pressor separtors. When the VRT is operating overhead gases. are routed to th 12 MW Weight % Helium C02 N2 methane ethane 0.0 propane isobutane n -butane isopentane n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224 -TM P Benzene Toluene Ethylbenzene Xylenes C8+ Heavies 32.4 0,5 0.1 Total VOC Wt % b/Ib-mol 1.3 MMsd per month I ead gas from the !sv pressor≥ separators is sent to the ECDsduing vapor resgveryunit dau.zx..-me. The VPT receives liquids from the Ernissioo are estimated using the displacement equation and a weighted average cf the. site -specific gas sampie dated 12/22;2014 (analysis date 4, 60., 20. Asia, VRU Inlet). and the VRT output results from the ProMax rriadei. . Displacement Equation Ex=Q'MW'Xx/C 3 of 14 C:\Users\jojones\Desktop \ MINE \TV\Oil & Gas \Syn Minor CPs for Serious \North Platte A-33\15WE0418.CP4_PA Separator Venting Emissions inventory Emission Factors Separator Venting Emission Factor Source Pollutant - Uncontrolled Controlled (Ib/MMscf) I (Ib/MMscf) (Gas Throughput) (Gas Throughput) VOC `.24S1 3766,2323 I ,d€iiga5 analysg Benzene 129.9049 3 f 7,72 Toluene 141,7078 _,� 3i3�cd ya i tye Ethylbenzene 7.£141 C.79917 dga na s ss}, dea g=_ ataly n tried gas ralym;- Xylene 25.3335 262: n -Hexane 1322,7712 66,29€,2 224TMP 722212 ._n_6 Pollutant Primary Control Device Emission Factor Source Uncontrolled Uncontrolled (Ib/MMBtu) Ib/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 [),'00',5 .._-205 .. a¢2,._{PN110/P6+ y;{P9,1100 't Y 2 (SO' PM2.5 6.0'075 iS 11285 SOx 0,0006 1 '355 NOx 0.flo8C 194,4590 do trial Flares A __. _�.�dustriaLFlat, CO 0-3100 20C, Pollutant Pilot Light Emissions Emission Factor Source Uncontrolled Uncontrolled (Ib/MMBtu) Ib/MMscf (Waste Heat Combusted) (Pilot Gas Throughput) PM10 0.0000 'sr �, 'rYg. $ d " JJ " , .Ilk f ��+'`•. -fl+n: 9"4- . PM2.5 0.0000 C SOx 0,0000 _ NOx 0,(]000 ., CO 0.9606 -3.:_,.-.5 Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM10 PM2.5 sox NOx VOC CO 0.1 r -t 0,1 ... € 1 21 0.1 ._ 0.1 .,_ 0,1 21 0.6 0.0 .;. 0.0 0,0 2 1,1 _s 1.1 1.1 11 194 555.5 555.5 27.8 555.5 27.8 4718 5.2 5.2 5.2 5.2 5.2 882 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 IMP 2502 2502 125 2502 125 2050 2090 105 2090 105 114 __. 5 114 & 669 669 33 669 33 19555 14555. 978 19555 978 10sa 10880 54 1080 54 Section 06- Regulatory SummantAnal sis Regulation 3, Parts A, B Regulation 7, Part D, Section ILB, F Regulation 7, Part D, Section II.B.2.e The control dosice for this separator is not subject to Regulation 7. Part D, Section 0.8.2.e (See regulatory applicability worksheet for detailed analysis) Source requires a pe=^i- Source is subject to Regulation 7, Part D, section 11.5,2, F 4 of 14 CAUsers\jojones\ Desktop \ MINE \TV\Oil & Gas \Syn Minor CPs for Serious \North Platte A-33\15WE0418.CP4_PA Separator Venting Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if thefacility has not been modified (e.g.., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of V0C greater than or equal to 40 tons per year in the ozone nonattainment area OR are emissions greaterthan or equal to 90 tons per year in the ozone attainment area? If yes, the permit wRl contain: -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A "Periodic Testing; Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Ye If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 08 -Technical Analysis Notes HHV, MW and mass fractions are based on a weighted average of LP separator gas (sampled 12/22/2014) and the VRT gas analysis results from the ProMax model. This method was established with CP2 issuance. EFs submitted vary slightly from those in CP2and CP3 permit notes, presumable due torounding differences, but permitted emissions are equal. Calculated EFs for toluene and 224-TMP do notmatchapplication exactly, again presumably due to rounding differences, but are within 1lb/yr uncontrolled. Combustion emissions from ECD.pilot lights are accounted for in the emissions for the condensate tank, since these units: share common control devices Section 09 - SCC Coding and Emissions Factors (For Inventory Use Only) AIRS Point # 007 Process # SCC Code 01 3--tmoi-e0 Flares Pollutant Uncontrolled Emissions Factor Control % Units PM10 16.9 0 ih/=y. MKT PM2.5 16.3 0 ifa,VMSC:- S0x 1.3 0 ._, ....:�.� N0x 154.5 0 IL .,,;t,^=.c,.- V0C 75324.6 95 ih,livi LsC€= CO 704.3 0 ph/rt,?tt15CE Benzene 169.6 95 l6fv.;'•_=13C Toluene 141.77 95 9b/M91SCT Ethylbenzene 7.7 - 95 l6/MMSCF Xylene 75.3 95 Ib/MisiSCF n -Hexane 1325.8 96 a,,,ISC- .5 224 TMP .3 1 _Ih/A gagCr 5 of 14 C\Users\jojones\ Desktop \ MINE \TV\0il & Gas \Syn Minor CPs for Serious \North Platte A-33\15WE0418.CP4_PA Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B -APEN and Permit Requirements 'Source is in the NencAtreindiedt Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section ll.D.1.a)7 2. Are total facility uncontrolled VOC emissions greater than 5TPY NO greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section ll.D.3)7 S indicate tsnares -,an-Anal yn - Aced ' NON -ATTAINMENT ` 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than (TPY(Regulation 3, Part A, Section ll.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,. NON greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section ll.D.2)7 Is ,.... _ asapermit Colorado Regulation 7, Part a, Section II 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? 'Source is sublect to Freddie -lion i, Part D, Section 11.6.2, E Section II.B.2- General Provisions for Air Pollution Control Equipment Used to Comply with Section II Section II.F- Control of emissions from well production facilities Alternative Emissions Control (Optional Sectiont a. Is this separator controlled by a back-up or altemate combustion device (i.e., not the primary control device) that is not enclosed? 'The control device for this separator is not subject to Regulat;on 7, Par: D, Seedon Section II.B.2.e-Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual /acts and circumstances. This document does not change or substitute forany law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend,""may,"'should,"and "can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must" and "required" are intended to describe controlling requirements under the terms of the Clean Air. Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. YeS Yes ''Source Rei Source Re ''Source Is s ;'The rontrr Storage Tani* Emissions Inventory Section 01 -Administrative Information (Facility AIRS ID: 123 County 9843 Plant 0'11 Point Section 02 - Equipment Description Details Storage Tank Liquid Detailed Emissions Unit Description: Eight (8) 800 barrel atmc Emission Control Device ons are routed to six (6) enclosed combustors (ECD 01-0 Chet achieve a minimum VOL' control efficiency of 95%. Description: Requested Overall VOC& HAP Control Efficiency%: 9SA Limited Process Parameter �i Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions -Storage Taak(s) Actual Throughput= 'Requested Permit Limit Throughput= 38,358.0 Barrels (bbl) per year 46,030.0 Barrels (bbl) per year Requested Monthly Throughput= 3309.4 Barrels (bbl) per month Potential to Emit (PTE) Condensate Throughput = Secondary Emissions - Combustion Device(s) Heat content of waste. gas= Volume of waste gas emitted per BBL of liquids produced = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 46,030.0 Barrels (bbl) per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = Control Device 5.'_ MMBTU per year 5,305.3 MMBTU per year 6,306.3 MMBTU per year 6 pilots at 18.5 scf/hr Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Condensate Tank Pollutant VOC Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Condensate Throughput) 5.5288 0.0290 0.0351 0.0020 0.0133 0.2393 0.0159 (70078 Control Device (Condensate Throughput) 0.0010 0.0001 0.0707 Uncontrolled Ilb/MMBtu) (waste heat combusted) Uncontrolled (Ib/bbl) (Condensate Throughput) Emission Factor Source Emission Factor Source PM10 PM2.5 0.0075 0.0075 0.0006 0.0680 0.3100 0.0010 0=.0010 00001 0.F'--93 0,0425 SOx NOx CO Pollutant Pilot Light Emissions Uncontrolled Uncontrolled (Ib/MMBtu) (Ib/MMscf) (Pilot Gas Heat Combusted) (Pilot Gas Throughput) Emission Factor Source PM10 PM2.5 3.=000 _.0000 0.0000 sox NOx VOC CO 0.0680 02280 0.3100 Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM10 PM2.5 50x NOx VOC CO 0.0 0.0 DC 0.0 0.0 ,:_. _.., 0!7 _._ 40 0.0 .,,.. 0.0 0.3 0.3 ... ..... 0.3 52.1 127.2 106.0 5.3 11272 1030.7 1.4 1-2 _._ 1.4 _, . _37.6 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene 13345 1112.4 55.6 1234.87 56.74 1615.7 13=6fi 67,3 1615065 80.78 92.1 76.7 3.8 52.06 4.60 7 of 14 C:\Users\jojones\Desktop \ MINE \TV\Oil & Gas \Syn Minor CPs for5erious\North Platte A-33\15WE0418.CP4_PA Storage Tank(s) Emissions Inventory Xylem n -Hexane 224 IMP • 612.2 510.2 9179.1 609.9 25.5 459.0 30.5 612.20 30.61 550.755 366.49 11015.0 11014.98 731.9 731.88 8 of 14 CAUsers\jojones\Desktop \MINE\TV\Oil & Gas \Syn Minor CPs for Serious \North Platte A-33\15WE0418.CP4_PA Storage Tank(s) Emissions Inventory Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B 'a a 3. _., _s a permit Regulation 7, Part D,Section I.C, D, E, F Storage tan! is subject to Regulation 7,Port O, Section. I.C-F Regulation 7; Part O,Section LOX Storage Tank is not subject ro Regulation 7, Section I,G Regulation 7, Part D,Section II.B, C.1, C,3 _ oragetank is subject to Regulation 7, Part 0, S__. ,,, lie 3._ le C.3 Regulation 7, Part D,Section. II.C.2 Steragetsnk is subject to Regulation on 7. Pert t., .3,2 Regulation 7, Part 0,Section ll.C.4,a.(i) Mirage Tank is not subject to Regulation .. .,..., Regulation 7, Part D,Section II.C.4a.(ii) .n , snot subject to Re . o. .., ... Regulation 6, Part A, NSPS Subpart Kb Storage Tank s not subject to DISPS R Regulation 6, Part A, NSPS Subpart 0000 Storage Tanks rot snbjeet to NSPS 0000 NSPS Subpart 0000a Se Do tank? not Ktej ect za t SPS 000Qa. Regulation 8, Part.E, MACE Subpart HH Storage Tank is not subject to tilAC HH (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic5ampling and Testing Requirements For condensate or crude oil tanks, does the company use the state default emissions factors to estimate emissions? dyes, are the uncontrolled actual. or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the controlled actual or requester) emissions for a condensate storage tank estimated to be greater than or equal to 80 tpy? If yes, the permit will contain an Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company use a site spedfic emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted (for produced water tanks, a pressurize liquid sample must be analyzed using flash liberation analysis)? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 08 - Technical Analysis Notes VOC and HAP EFs from CP3. Tanks were modeled w/out VRTlfor conservative estimate, though VRT is still on site and opera NOK. and CO limits not included in CP4 since below APEN:reporting levels for this point. Section 09 -SCC Coding and Emissions Factors ( For Inventory Use Only). AIRS Point # 011 Process# 01 SCC Code Uncontrolled Emissions Pollutant Factor Control% Units PM10 4 lb/1,000 gallons Condensate throughput PM2.5 0.04 G Ib/1,000:gallons Condensate throughput SOx 0,00 P 16/1,000 gallons Condensate throughput • NOx 3.32 G lb/1,000 gallons Condensate throughput VOC 131.64 95 lb/1,000 gallons Condensate throughput CO 1-_5 lb/1,000 gallons Condensate throughput Benzene Gv, 95 lb/1,000 gallons Condensate throughput Toluene .8= 95 lb/1,000 gallons Condensate throughput Ethylbenzene 0.2S 95 lb/1,000 gallons Condensate throughput Xylene 3.32 95 lb/1,000 gallons Condensate throughput n -Hexane 5.72 95 lb/1,000 gallons Condensate throughput 224 TMP 9.38 95. lb/1,000 gallons Condensate throughput 9 of 14 CAHsers\iojones\ Desktop \ MINE \TV\Oil & Gas \Syn Minor CPs for Serious \North Platte A-33\15WE0418.CP4_PA Storage Tank Regulatory Analysis Worksheet The regulatory requirements below are determined based an requested emissions. Colorado Regulation 3paris A and 8-APEN and Permit Requirements c is In the Nun-Attainmen kArea ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this Ind Mclual source greater than 2 TPY (Regulation 3, Part A, Section ll.D.1.a)? ® Source Requires an APEN. Go to 2. Is the construction date (service date) priorto 12/30/2002 and not muffled afterl2/31/20@ (See PS Memo 05-010efinttions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Aretotal facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part&Section ll.D.3)7 I'-ou have Indicated thatseurc i. r, l;.=`-.. ._a:nmem Amu NON -ATTAINMENT 1- Are uncontrolled emkslons from any criteria pollutants fromthis Individual sourcegreMerthan 1TPY(Regulation 3, Part A, Section ll.D.1.M7 2. Is the construction date (service date) priorto 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05.01 Definitions 1-32 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greaterthan s TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section ll.D.2)7 IS,,.:. e: Colorado Regulation 7, Pert D. Section I.C-F & G 1. Is this storagetank located In the 8 -hr ozone control area or any ozone nonattainmeM area or attainment/maintenance area (Regulation 7, Part D, Section I.A.1)7 2. N this storage tank located at oil and gas operations that collect, store, or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processing plant (Regulation 7, Part D, Section l.A.1)7 3. Is this storage tank located at a natural gas processing plant (Regulation 7, Part D, Section I -G)7 4. Does this storage tank contain condensate? 5. Does this storage tank exhibit "Flash"(e.g.storing nommabilized liquids) emissions (Regulation 7, part D, Section l.G.2)7 6. Are uncontrolled actual emissions of thk stom eta k equalrgreMerthan 2 tom per year VOC (Regulation 7, Part D,Sectonl D3a(ii)7 'Storage trunk IS SittljeCt TT- T Part D, Section I.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage Part D, Section I.C.2— Emission Estimation Procedures Part 0, Section I.D—Emissions Control Requirements Part 0, Section LE —Monitoring Part D, Section I.F—Recordkeeping and Reporting _r ] Sarno, ., Part D, Section I.G.2- Emissions Control Requirements Part D, Section I.C.1.a and b —General Requirements for Air Pollution Control Equipment —Prevention of Leakage Colorado Regulation], Part D, Sectron II 1. Is this storagetank located at a transmission/storage facility? 2. Is this storagetank[ located at an oil and gas exploration and production operation, well production facility', natural gas comprmsor Mation'or natural gas processing plant (Regulation 7, Part D, Section II.C)? 3. Does this storagetank have a fixed roof 'Regulation 7, Part 0, Section li.A.20)? 4 Are uncontrolled actual emissions of th st g k q rgreater than 2 tons per year VOL (Re elation], Part D, section ll.C.1-c)? stun.. _ lm, oRegoi,--on. v, Tocnonll, 8.4.141 C.3 ' Part D, Section ll.B- General Provisions for Air Pollution Control Equipment and Prevention of Emissions Part 0, Section II.C.1 • ':missions Control and Monitoring Provisions Part D, Section II.C.3 - Recordkeeping Requirements S. Doesthe storage tank contain only stabs -zed liqulds(Regulation 7, Part D, Section ll.G2.6)7 Part D, Section RC, • Capture and Monitoringfor Storage Tanks fitted with Air Pollution Control Equipment is the controlled storage tank locared at a well produrtion facility, naturalgm compressor station, or natural gas processing plant constructed on or after May 1, 2024 or located Ma facility that was modified on or after May 1, 2020, such 6. that an additional controlled storage vassal is constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water (Regulation ], Part o, section II 4.a.(i)7 %NM Yes Yes t fittal Go to next question Source Requires a permit Source Requires an APEN. Go to Go to neM qumtlon Source Requires apermit Continue - You have indicated* Continue - You have indicated* Storage Tank is not subject to RE Continue - You have indicated lit Go to the next question - You lea Go to the next question Source is subject to parts of Rego fimm.Mr41Source is subject to all provision• Is the controlled storage tank located at a well production facility, natural gas compressor station, or natural gas pro sing plant constructed on or after January 1, 2023 or located atat wm mod'died on or after 7, 2021, such that an additional controlled storage vessel Is constructedto receive an anticipated increase In throughput *hydrocarbon liquids or produced water (Regulation 7, Part 0, Section ll.C.4.a.(ii)7 40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greaterthan or equal to 75 cubic meters (mel ("472 BBIs] (40 CFR 60.110b(a))? 2. Does the storage vessel meet the following exemption In 60.111b(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 in' [-10,000 BBL] used for petroleum' or condensate stored,processed, or treated prior to custody transfer' as defined in 60.1116? 3. Was thisstorage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23,1984(40 CFR 60.110b(a))? 4. Does the tank meet the definition of "storage v ser"In 60.111bt s. Does the storage vessel store a"volatile organic liquid(VOL)"'as defined in 64.1116? 6. Does the storage vessel meet any one of thefollowing additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa [^29.7 psi] and without emissions to the atmosphere (60.1106(d)(2))?; or b. The design capacity 6 greater than or equal to 151 ms (-950 BBL] and stores liquid with a maximum true vapor pressures less than 3.5 kPa (60.1106(6))7; or c. The design capacity Is greater than or equal to 75 Ma ('"472 BBL] but less than 151 ms [-950 BBL] and stores a liquid with a maximum true vapor pressure' less than 15.0 kna(60.130b(b))7 7. Does the sorage tank meet a@her one of the following exemptions from control requirements: a. The design capacity is greater than or equal to 151 ms [-950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa?) or b. The design capacity Is greaterthan or equal to 75 Be [-472 BBL] but less than 151 m' [-950 BBL] and stores a liquid with a maximum true vapor pressure greaterthan or equal to 15.0 kPa but less than 27.6 kna? I>t.ag4Tank is.tot xipi:srtt;. t.--nb 40 CFR, Part 60. Subpart 0000/0000a, Standards of Performance for Crude Oil and Natural Gas Production. Transmission and DistibMfon 1. Is this storage vessel located at a facility in the onshore oil and natural gm production segment, natural gas processing segment or natural gas transmission and storage segment of the Industry? 2. Wasthis storage vessel constructed, reconstructed, or modified(see definitions 40CFR,60.2) between August 23, 2011 and September 18, 20157 3. Was this storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after September 18, 20151 4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6tons per year? 5. Does thb storage vessel meet the definition of"storage vessel"' per 60.5430/60.5430a? 6. Is themorlgeyvessel abject to and controlled In accordance with re ulrements for store evessels In 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Sub art HH7 Tani! is t suTlertt NSPS C'G i0 [Note: If a storage vessel Is previously determined to be subject to NSPS 0000/0000a due to emissions above 6 tons per year VOC on the applicability determination date, it should remain &Minato NSPS 0000/0000a per 60.5365(e)(2)/6D.5365a(e)(2) even It paten -bpi VOC emissions drop below 6 tons per year] 40 CFR, Part 63. Subpart MACT HH, Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the fallowing criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR b. A facility that processes, upgrades or stores natural gas priorto the point at which natural gas enters the natural gas transmission and storage source category or b delivered to a final end user' (63.760(a)(3))? 2. Is the tank located M a facility that k major" for HAPs? 3. Does thetank meet the definition of"storage vessele. in 63.7617 4. Does the tank meet the definition of"storage vessel with the potential for flash emissions"' per 63.7617 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Sub art 0000? Subpart A, General provisions per 463.764 (a) Table 2 463.]66. Emissions Control Standards 463.773 Monitoring 463.774 - Recordkeeping 463.7]5 -Reporting RACT Review RACT review Is required If Regulation 7 does not apply AND lithe tank Is in the non -attainment area. lithe tank meets bath criteria, then review RACT reguiremerds. Disclaimer Storage Tank Is not subject to Re Go to the next question Storage Tank is not subject NSPS 01* Continue -You have indicated th Go to the question 4. Storage Tank Is not subject NSPS Storage Tank Is not subject NSPS ontinue - You have indicated th Storage Tank Is not subject MAC Thiselocumenl assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Qualri Control Commission regulations. This document is not e rule arregulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This docurtcnt does not change or substitute for any law, regulation, r any other legally binding requirement and is not legally enlbrceabfe. In the event of any conflict between the language of this document and the language olthe Clean Air Act„ its implemenh'ngsegulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as`recommend,"'may,""should,"and'can,"is intended to describe APCD interpretations end recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Hydrocarbon Loadout Erthssions I'.ivencof'y Section 01 -Administrative Information Facility AIRS ID: 123' County 9D43 Plant 012 Point Section 02 - Equipment Description Details Detailed Emissions Unit Hydrocarbon Loadoutfo Tanker Trucks. Description: Emission Control Device Description: Erdisslgna are routedtssix(5) enclosed combustors {ECG 01-08)- - Is this loadout controlled?' t` Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded= Requested Permit UmitThroughput = Potential to Emit (PTE) Volume Loaded = 46;t#30 Barrels (bbl) per year 9S Barrels (hbl) per year 4F Barrels (bbl) per year Requested Monthly Throughput= 3:104 Barrels (bbl) per month Secondary Emissions - Combustion Device(s) Heat content of waste gas= Actual Volume of waste gas emitted per year = Requested Volume of waste gas emitted per year= Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = .3153 Btu/scf scf/year . ,T) scf/year Potential to Emit (PTE) heat content of waste gas routed to combustion device = MMBTU per year • MMBTU per year • MMBTU per year Control Device Pilot Fuel Use Rate: Pilot Fuel Gas Heating Value: •k scfh 0 Btu/scf .: MMscf/yr .. v MMBTU/yr Section 04- Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Does the hydrocarbon liquid loading operation utilize submerged fill? Pollutant Hydrocarbon Loadout Uncontrolled Controlled (Ib/bh0 (Ih/bbl) (Volume Loaded) (Volume Loaded) Emission Factor Source ®' ®*• ® rs .` ® d' ® MIIMZESERMMII Pollutant Uncontrolled (Ib/MMBtu) Uncontrolled Ilb/bbl) (waste heat combusted) Pollutant Pilot Light Emissions Uncontrolled (Ib/MMBtu) Uncontrolled Ills/MMscf) (Pilot Gas Throughput) (Waste Heat Combusted) 0.0000 0.0000 .IIEMIEMMIIIIIIIIKEMII Emission Factor Source Emission Factor Source 12 of 14 C:\Users\jojones\Desktop\MINEMOil & Gas \Syn Minor CPs for Serious \North Platte A-33 \15WE0418.CP4_PA Hydrocarbon Loadolat Ernlsslons InJentor;r Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly limits Controlled (Ibs/monthl PM30 PM2.5 SOx NOx VOC CO 0.90 0.00 0.00 0.00 O,OO 9 0 00 __ '.'79 _,..,_ 0 CO 0.00 .. 0.00 0,00, ... _.. ADD 0.11 5.43 „,7 ,_ _-_- 0.04 ._. ., _t 0334 0.04 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224TMP 19 19 _ 19 _ O 0 165 ._.. - aoc Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B _, 1evn ,t Regulation 7 Part D Section II.C.5. (See regulatory applicability worksheet for detailed analysis) twOrortobott tittottis Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? Ayes, the permit will contain initial and periodic compliance testing in accordance with P5 Memo 2002 7, — Section 08 - Technical Analysis Notes The Volume. of waste gas routed to the ECOws alculateedbased pn a GOR of 1,795cf/blit., cheat content(HHV) of waste gas was estimated at 3,1538tu/scf The application did not specify how these values were determined, however, since the estimated volume (0,08 MMscf/yr) is greater than the volume estimgt. itU5ing the default method incfuded in this worksheet (0.06 MMscf/yr, per calculation specified below) and the assumed HHV is higher that the accepted value for condensate tank waste gas streams in the DJ Basin (2255 Btu/set; per PS Memo 14-3, Section 5.13), the values provided by the applicant were accepted. - Mehod included in PA worksheet: Volume (set/yr) = [Uncontrolled VOC (ton/year)r[20001b/tonj\[Molecular W eight (Ib/Ib-mol)]*[379 scf/Ib-mol) MW of vapors estimated at 65 lb-lb-mol based on AP -42 Table 7.1-2 and RVP 9liquid stored. Combustion emissions from pilot lights are accounted for in the emissions for the condensate tank, since these share common control devices. Section 09 - SCC Coding and Emissions Factors (For Inventory Use Only), AIRS Point # 012 Process # 01 SCC Code 4-03-001-02 0ctid40O1 Clo0403004.4_tenot. ee Uncontrolled Emissions Pollutant Factor Control% Units PM10 t 0 lb/1,000 gallons transferred PM2.5 C._3 0 lb/1,000 gallons transferred 50x -.r_ D lb/1,000 gallons transferred NOx .,__ 0 lb/1,000 gallons transferred VOC 95 lb/1,000 gallons transferred CO _.04 0 lb/1,000 gallons transferred Benzene 9.5 lb/1,000 gallons transferred Toluene A00 95 lb/1,000 gallons transferred Ethylbenzene cum 35 lb/1,000 gallons transferred Xylene 3.00 95 lb/1,000 gallons transferred n -Hexane 0.09 95 lb/1,000 gallons transferred 224 TMP _.C-„ _., lb/1,003 gallons transferred 13 of 14 C:\Users\jojones\Desktop \ MINE \TV\Oil & Gas \Syn Minor CPs for Serious \North Platte A-33\15WE0418.CP4_PA Hydrocarbon Ina dont Regulator,/ Analysis Worksheet The regulatory requirements below ore determined based on requested emissions and throughput. Colorado geeulatbn 3 ParttiA find 8 -.EN and P_esmk Reggieameats 15,441s in tha ricu Attainrox .-_2m ATTAINMENT 1. Are uncontrolled actual emisslons from any criteria pollutants from this individual source greater than 2TPY lRegulation 3, Part A, Section II.O.l.al? 2. Is Me loadout located at an exploration and productions, (e.g., well pall (Regulation 3, part B,3. 5ecddn II.O.I.IIl Is the loadout operation loading lam than 10,000 gallons (238 Oebs) of crude oil per dayon an annual average hash, 4. Is the loadout operation loading less. than 6,750 bbls per year of condensate via splash MR 5. Is the loadout operation loading less than 15,308 bb1s per year of condensate via submerged fill procedural 6. Are meal facility uncontrolled VOC emissions greaser than 5TPy, Nat greater tha.0 -MY era, emissionsyreater than to TPY(Regulation 3, part a, ...I 11.0.3(? 'You have inJlcated that:aurde_rn:b-we .icinment Mee rvolyAITPIIYmw? 1. Pre =control. emission from a, criteria pollutants from this individual source. greater .an l TPy (Regulation 3, Pan A, SectiovllO.la(? 2. Is the loadout located at an exploration and production site (e.g., well padl (Regulation 3, part%Section II.O.12)? 3. Ls the losd.t operation loading less than 30,000 gallons (238 BBta) ofcrude al per clay man annual average basis? A .[ Is the loadoperation loading less than 5,750 bids per yearof condensate via splash fill, Is the loadout operation loading less than 16,308 bbls per year ofcondensate via submerged- gl procedure, 6 Are total facility uncontro•d VOC emissions from the. greater than 2TPY NO2 greater than 5 T. or CO emissions greater Man loTpV lRegulaton3 Part 5, Section II. D.2), C 5,06.145, 1. Is this condensate storao M, hydrocarbon liquids loadout located at a well production facility,nalo. gas compressor station or amoral gas processing plant? 2Does,e facility have h b liquids loadout to trans porevenlces greater than or equal to 5,000 barrels? ryir. <:c .... .. _.:.,=;x.igs:biect to Pevualfut rPan G Section l i- Section II.C5.a10-Compliance Schedule Section S.a.(iti-0,ralion without Venting Section s.a.(iip- Lodi.[ Equipmentopootion and maln.ance Secti.Il.e.5.a.(Ivl • Load°, observations and operator Training s.a.fvl -R cords Section ITC,34.(vil- Requirements for , Pmlueon Control Equipment Disclaimer This document assists operators with determining eppficabllliy of certain requirements of the Clean Alr Act. itslmpkmenCeg regulation, end Air Quality Control Commission regulations. This document nota rule or regulatbn and the analysis it contains may not apply to s particular situation based upon the Individual/ is and circumstance:. This document dims not change or substitute ter eny law, regulation,or any other legally binding requirement and is not legally enlaceable In the amigo/any conflict between the l®guage of this document end the language of the Clean Air Act„ its implementing regulations, end Air Quality Control Commission regulations. Me language of the statue wregulafion will control. The user/nanmandeto y language such as "recommend,'"may,""should"and'ban"is Intended to describe APCO interpretations and recommendations. Mandatory terminology such es"must"end" eakeC ale intended lodescdbe controlling esqulrernonts unearth°hxn: of the Clean Air Act and Air quality Contra Commission regulefioxs, but Mls document does not establish lonely b'ndrg requirements in aidolifsen "N_ Soto nextquestidn 3H. Soto the next quest,., xrvi Go tone. questlon Go boastqueston to neXt<Me., The'gado, req.esa permit Go to next question. Source is subject to.6islabonJ Part OSection II.G5. Superseded by APEN Addendum received by email on 12/11/2020. JJones - APCD Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 15WE0418 AIRS ID Number: 123 / 9D43 /007 Section 1 - Administrative Information Company Name: Bonanza Creek Energy Operating Company, LLC (BCEOC) Site Name: North Platte A-33 Production Facility (COGCC #438202) Site Location: NWNW, 5N, 33, 63W 40.362217, -104.448806 Mailing Address: 410 17th Street, Suite 1400 (include Zip Code) Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Addressz: Alisson Soehner (303) 803-1752 asoehner@bonanzacrk.com i Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. z Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 432264 GOIORADO ' k�rtU6tart�romm�l, Permit Number: 1 5WE041$ AIRS ID Number: 123 /9D43/007 Section 2 - Requested _Action ❑ NEW permit OR newly -reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit lj Change permit limit ❑ Transfer of ownership° ❑ Other (describe below) OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: Requesting new throughput and emission limits. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. ° For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: (6) enclosed combustors Low pressure gas from separators controlled by six Company equipment Identification No. (optional): LPGFL For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: El Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? days/week weeks/year Yes Yes Yes ❑ No (] No ❑ No S COLORADO Deyortmwtl d P Nk HWON 6 [nnw..nrm Permit Number: 1 5 y y E04 1 8 AIRS ID Number: 123 /9D43/ 007 Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑r Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ No Vent Gas Heating Value: 2,152 BTU/SCF Requested: 16.49 MMSCF/year Actual: 16.49 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 37.8 vOC (Weight %) 67.9552 Benzene (Weight %) 0.0915 Toluene (weight %) 0.0363 Ethylbenzene (weight %) 0.0015 Xylene (weight %) 0.0038 n -Hexane (Weight %) 0.6694 2,2,4-Trimethylpentane (weight %) 0.0280 Additional Required Documentation: Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. COLORADO H..611. swine MWU 6 Ex+�rnmnt Permit Number: 1 5WE041 8 Section 5 - Geographical/Stack Information AIRS ID Number: 123 /9D43/007 Geographical Coordinates (Lotitude/Longitude or UTM) 40.362217, -104.448806 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. ECD 01-06 -35 500 TBD TBD Indicate the direction of the stack outlet: (check one) Upward ❑ Horizontal ❑ Downward ❑ Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) Circular Interior stack diameter (inches): 48 ❑ Square/rectangle Interior stack width (inches): ❑ Other (describe): Interior stack depth (inches): Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: 4.06 MMBtu/hr Type: Enclosed Combustor Make/Model: Six (6) Leed 48" Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: 500 95 98 Waste Gas Heat Content: Constant Pilot Light: ❑ Yes ® No Pilot burner Rating: 2,152 N/A Btu/scf MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: COLORADO Permit Number: 15WE0418 AIRS ID Number: 123 /9D43/007 Section 7 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? El Yes ❑ No If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Description Collection Efficiency (% of total emissions captured by control equipment) Control Efficiency (% reduction of captured emissions) PM SOX NO,, CO VOC ECD 100 95 HAPs ECD 100 95 Other: From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source: Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissionsb (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (torts/year) PM 40 0 ug/L AP -42 0.22 0.22 0.22 0.22 SOX 0.00032 Ib/MMBtu AP -42 0.01 0.01 0.01 0.01 NOX 0.068 Ib/bMMBtu AP -42 1.21 1.21 1.21 1.21 CO 0,310 Ib/MMBtu AP -42 5.52 5.52 5.52 5-52 VOC 67.686.25 Ib/MMsd Gas Analysis 558.08 27.91 558.08 27.91 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 8 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? ❑ Yes ❑ No If yes, use the following table to report the non -criteria pollutant (HAP} emissions from source: Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (ibslyear) Controlled Emissionsb (lbs/year) Benzene 71432 91.14 Ib/MMBtu Gas Analysis 1,504 76 Toluene 108883 36.16 Ib/MMBtu Gas Analysis 588 30 Ethylbenzene 100414 1.49 Ib/MMBtu Gas Analysis De Minimis De Minimis Xylene 1330207 3.78 Ib/MMBtu Gas Analysis De Minimis De Minimis n -Hexane 110543 666.75 Ib/MMBtu Gas Analysis 10.996 550 2,2,4-Trimethylpentane 540841 27.89 lb/MMBtu Gas Analysis 460 24 Other: 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. so.COLORADO dn*u��t a vueate Hea. ..1+nwnn.mt Permit Number: 15WE0418 AIRS ID Number: 123 /9°43/007 Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 6/04/2020 Signature of Legally Authorized Person (not a vendor or consultant) Date Alisson Soehner Environmental Engineer, Air Quality Name (print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance Ij Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: For more information or assistance call: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Small Business Assistance Program (303)692-3175 OR (303) 692-3148 APCD Main Phone Number Make check payable to: (303)692-3150 • Colorado Department of Public Health and Environment fee COLORADO lasparunentot Noe. Vairironmem APEN Addendum received by email on 12/11/2020. JJones - APCD Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 15WE0418 AIRS ID Number: 123 / 9D43 /007 [Leave blank unless APCD has already assigned a permit r and AIRS ID] Section 1 - Administrative Information Company Name: Bonanza Creek Energy Operating Company, LLC (BCEOC) Site Name: North Platte A-33 Production Facility (COGCC #438202) Site Location: NWNW, 5N, 33, 63W 40.362217, -104.448806 Mailing Address: 410 17th Street Suite 1400 (Include Zip Code) � Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address2: Alisson Soehner (303) 803-1752 asoehner@bonanzacrk.com t Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. z Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-211 - Gas Venting APEN - Revision 07/2020 1 I COLORADO DepaztaenialPublic Heal. b Envieonmene Permit Number: 15WE0418 AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action 123 /9o43/007 ❑ NEW permit OR newly -reported emission source OR- (] MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ID Change permit limit ❑ Transfer of ownership' P ❑ Other (describe below) - OR APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ID Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Requesting new throughput and emission limits. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed mpleted Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: (6) enclosed combustors Low pressure gas from separators controlled by six Company equipment Identification No. (optional): LPGFL For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/da Y days/week weeks/year Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-211 Gas Venting APEN - Revision ©7/2©2© 0 Yes Yes Yes ❑ No No ❑ No COLORADO 2' n�,w.m�e.,t a wets � xw�n s Enwanmen, Permit Number: 1 5WE041 8 AIRS ID Number: 123 /9D43/007 [Leave blank unless APCD has already assigned a permit 4 and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes Gas Venting Process Parameters: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ No Vent Gas 2 272 BTU/SCF Heating Value: Requested: 14.75 MMSCF/year Actual: 14.75 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 40.1 VOC (Weight %) 71.2810 Benzene (Weight %) 0.1605 Toluene (Weight %) 0.1340 Ethylbenzene (Weight %) 0.0073 Xylene (Weight %) 0.0429 n -Hexane (Weight %) 1.2546 2,2,4-Trimethylpentane (Weight %) 0.0692 Additional Required Documentation: ❑✓ Attach a representative gas analysis (including BTEX It n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. Form APCD-211 - Gas Venting APEN - Revision 07/2020 COLORADO 3 I m«A,Btte I timifh B En�lronmant Permit Number: 15WE0418 AIRS ID Number: 123 /9D43/007 [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.362217, -104.448806 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stacks@ No. ECD 01-06 Discharge Height Above Ground Leve (Feet) -35 500 Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Downward ❑ Horizontal ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): 48 ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): TBD TBD ❑ Upward with obstructing raincap Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: ❑ Combustion Device: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Pollutants Controlled: VOC, HAPs Make/Model: % Rating: 3.83 MMBtu/hr Type: Enclosed Combustor Make/Model: Six (6) Leed 48" Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: 500 Waste Gas Heat Content: Constant Pilot Light: ❑ Yes ❑✓ No Pilot burner Rating: 2,272 N/A Btu/scf MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 07/2020 !COLORADO 4 , 4ePar:rviiPn I km+tw6 [nmronmme Permit Number: 1 5WE041 8 AIRS ID Number: 123 /9D43/ 007 [Leave blank unless APCD has already assigned a permit u and AIRS Section 7 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑Q Yes ❑ No If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Pollutant Control EquipmentDescription Overall Requested', Control Efficiency'' (% reduction in emissions) PM SOX NO. CO VOC ECD 95 HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source: Pollutant . Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limfit(s)s Uncontrolled Basis Units Source Mfg 'etc Uncontrolled Emissions (tons/year) Controlled Emiss ns6 (tons/ ear .0.20 Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM 40.0 ug/L AP -42 0.20 0.20 0.20 SOx 0.00025 Ib/MMBtu AP -42 0.01 0.01 0.31 0.01 NO. 0.068 Ib/MMBtu AP -42 1.15 1.15 1.15 1.15 CO 0.310 Ib/MMBtu AP -42 5.21 5.21 5.21 5.21 VOC 75,324.65 Ib/MMscf Gas Analysis 555.52 27.78 555.52 27.78 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 8 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? ❑✓ Yes ❑ No If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units ' Source (AP -42, Mfg., etc.) Uncontrolled Emissions ( Y ibsi ear ) Controlled Snissionsb (tbs/year) Benzene 71432 169.60 lb/MMscf Gas Analysis 2,502 126 Toluene 108883 141.60 lb/MMscf Gas Analysis 2,090 106 Ethylbenzene 100414 7.71 lb/MMscf Gas Analysis De Minimis De Minims Xylene 1330207 45.33 lb/MMscf Gas Analysis 670 34 n -Hexane 110543 1,325.77 lb/MMscf Gas Analysis 19,556 978 2,2,4-Trimethylpentane 540841 73.13 lb/MMscf Gas Analysis 1,080 54 Other: 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Form APCD-211 - Gas Venting APEN - Revision 07/2020 'COLORADO 5 I Mgt We I a." Permit Number: 15WE0418 AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification 123 i 9D43 / 007 I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. Signature of Legally Authorized Person (not a vendor or consultant) Date Alisson Soehner Environmental Engineer, Air Quality Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance 0✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $216.00 to: For more information or assistance call: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Small Business Assistance Program (303)692-3175 OR (303) 692-3148 APCD Main Phone Number Make check payable to: (303) 692-3150 Colorado Department of Public Health and Environment Form APCD-211 - Gas Venting APEN - Revision 07/2020 Akti,AtifliptiCOLORADO 6 I HM6�al ` 12/15/2020 State.co.us Executive Branch Mail - BCEOC North Platte A-33 syn-minor application STATE OF COLORADO Jones - CDPHE, Joshua <joshua.jones@state.co.us> BCEOC North Platte A-33 syn-minor application Patrick Dilsaver <PDilsaver@bonanzacrk.com> Thu, Dec 10, 2020 at 10:32 AM To: "Jones - CDPHE, Joshua" <joshua.jones@state.co.us>, "pdilsaver@slrconsulting.com" <pdilsaver@slrconsulting.com> Cc: Alisson Soehner <ASoehner@bonanzacrk.com> Hey Josh, I just copied responses below and have several attachments. Let us know your thoughts and we will work to get anything out by the deadline! LPGFL (point 007) 1. In the previous issuance of 15WE0418, BCEOC requested the reference to the Vapor Recovery Tower (VRT) to remain in the description for this point in the permit to keep open the option of returning the VRT to service. Is the VRT still at this facility and does BCEOC want to keep the option to operate it? If so, emissions calculations should be revised according to the EFs from the previous issuance, which incorporate emissions from the LP separators as well as the VRT. The VRT is still onsite but not in use. We always prefer to keep operational flexibility if possible, so we would like to keep the option. I attached a revised calculation sheet which I believe reverts back to the emission factors that included VRT from Issuance 2. I had to revise the permitted flow rate to keep permitted emissions relatively the same. If this is acceptable we can provide redlines or a "clean" APEN if that is helpful. Let us know your thoughts. 2. The O&M plan for separator flaring needs to be revised according to language in the version recently accepted by the Division. My reference given for this is the O&M plan for point 010 at the Antelope P-17 production facility (12WE2919 / 123-9A53). This includes the addition in Section 4 — Monitoring Requirements of the method for determining the volume of separator gas using a calculated ratio of separator gas to total gas based on flash factors and applying it to the measured total when a negative flowrate is calculated by standard methods. This is in place of the flow to the separator being assumed to be zero. This also includes removal of last paragraph that begins "In the event the flow meter data is missing or invalid...". Because the permit requires a flow meter to monitor separator gas flared, this would seem to offer a means of alternative compliance, which is not the intent of the O&M plan. If you would please revise the O&M plan for point 007 and send it to me. Revised and attached. CNDTK-01 (point 011) 3. NOX and CO emissions for the condensate tank battery are calculated based on a waste gas flow of 16.97 scf/bbl. Can you verify for me where this value came from? I calculated a value of 49.00 scf/bbl based on results of the ProMax model run submitted in the application for Issuance 3 (0.0445915 MMscfd Tank Losses, 910 bbl/day Sales Oil). Also, the waste gas heat content was estimated at 2712 Btu/scf HHV. This seems to be from the ProMax model run results provided in the application for the initial issuance. A heat content of 2796 Btu/scf is given in the model run for Issuance 3. I believe NOX and CO emissions should be calculated using waste gas values from the model used to calculate the VOC emission factor. I got NOX at about 0.31 tpy and CO at 1.4 tpy including pilot light emissions. https://mail.google.com/mail/u/0?ik=6fb81 abf08&view=pt&search=all&permmsgid=msg-f%3A1685713372936728081 &simpl=msg-f%3A168571337293... 1/2 12/15/2020 State.co.us Executive Branch Mail - BCEOC North Platte A-33 syn-minor application Please let me know if you agree. If you agree, can you please submit a revised calculation sheet and I can red -line the APENs and provide BCEOC with copies. I agree with this, revised calculations attached. 4. In the O&M plan provided for the condensate tank, in Section 4 — Monitoring Requirements, the check box is marked indicating that these tanks are not subject to the STEM requirements of Reg. 7, Section XVII.C.2 and C.3 (now Part D, Section II.C.2 and II.C.3). It seems these tanks are subject to STEM requirements, so, with your approval, I will red -line the O&M plan to check the box saying they are subject and send a copy for BCEOC's records. Yes, these tanks should be subject to STEM, we will keep the redlined O&M for our records, thanks! From: Jones - CDPHE, Joshua[mailto:joshua.jones@state.co.us] Sent: Tuesday, December 08, 2020 4:29 PM To: Patrick Dilsaver <PDilsaver@bonanzacrk.com>; pdilsaver@slrconsulting.com Cc: Alisson Soehner <ASoehner@bonanzacrk.com> Subject: [EXTERNAL] BCEOC North Platte A-33 syn-minor application External Sender: Use caution with links/attachments [Quoted text hidden] 3 attachments erui _SEP OM.pdf 70K -11 Copy of North Platte A-33 Emissions 20200602 CNDTKRedlines.pdf 17K — NP A-33 LPGFL_VRT Calc Redlines 20201210 .pdf 72K https://mail.google.com/mail/u/0?ik=6fb81 abf08&view=pt&search=all&permmsgid=msg-Wa3A1685713372936728081 &simpl=msg-f%3A168571337293... 2/2 12/15/2020 State.co.us Executive Branch Mail - BCEOC North Platte A-33 syn-minor application STATE OF COLORADO Jones - CDPHE, Joshua <joshua.jones@state.co.us> BCEOC North Platte A-33 syn-minor application Leah Althoff <lalthoff@slrconsulting.com> Fri, Dec 11, 2020 at 12:02 PM To: "Jones - CDPHE, Joshua" <joshua.jones@state.co.us>, Patrick Dilsaver <pdilsaver@slrconsulting.com> Cc: Patrick Dilsaver <PDilsaver@bonanzacrk.com>, Alisson Soehner <asoehner@bonanzacrk.com> Hi Josh, Please find the updated APENs for the CNDTK and LPGFL attached. Thanks! SLR` Leah Althoff 970-999-3978 970-494-0805 612-770-3941 lalthoff@slrconsulting.com SLR International Corporation 1612 Specht Point Road, Suite 119, Fort Collins, CO 80525 Confidentiality Notice and Disclaimer This communication and any attachment(s) contain information which is confidential and may also be legally privileged. It is intended for the exclusive use of the recipient(s) to whom it is addressed. If you have received this communication in error, please e-mail us by return e-mail and then delete the e-mail from your system together with any copies of it. Any views or opinions are solely those of the author and do not represent those of SLR Management Ltd, or any of its subsidiaries, unless specifically stated. From: Jones - CDPHE, Joshua <joshua.jones@state.co.us> Sent: December 11, 2020 8:44 AM To: Patrick Dilsaver <pdilsaver@slrconsulting.com> Cc: Patrick Dilsaver <PDi!saver@bonanzacrk.com>; Alisson Soehner <asoehner@bonanzacrk.com>; Leah Althoff <lalthoff@slrconsulting.com> Subject: Re: FW: [EXTERNAL] BCEOC North Platte A-33 syn-minor application [Quoted text hidden] 2 attachments APEN 205_20201211.pdf 306K APEN 211_20201211.pdf 281K https://mail.google.com/mail/u/0?ik=6fb81 abf08&view=pt&search=all&permmsgid=msg-f%3A1685809641458252847&simpl=msg-f%3A168580964145... 1/1 Bonanza Creek Energy Operating Company, LLC. - North Platte A-33 Production Facility (COGCC 16438202) Low Pressure Gas Flaring Emission Calculations Source Type: Enclosed Flare Heat Input: 3.83 MMBtu/hr LP Seprator Gas Annual Flow Rate (a): 14.75 MMscf/yr Average Hourly Flowrate (a): 1,684 scf/hr Total Annual Flowrate: 14.75 MMscf/yr Total Gas to Oil Ratio: 146.83 scf/bbl Estimated HHV (b): 2,272 Btu/scf Enclosed Flare VOC Control Efficiency: 95% Molecular Weight (b): 40.1 Ib/Ib-mol H2S Content of Fuel (b): 3.3 ppm H2S Operating Hours: 8,760 hr/yr Pollutant Emission Factors 1`I Emissions lb/hr (d)• (e), if) tpy 191 CO2 fht 305,231 Ib/MMscf 513.94 2,251.08 N2O 0.000221b/MMBtu 0.001 0.0037 NO„ 0.0681b/MMBtu 0.260 1.15 CO 0.3101b/MMBtu 1.187 5.21 SO2 0.000251b/MMBtu 0.001 0.01 PMio 40.0 pg / L 0.04 0.20 PM2.5 40.0 pg / L 0.04 0.20 Pollutant Wt % of Gas (b) Emission Factor 1'I (Ib/MMscf) VOC Emission Rates m Uncontrolled Controlled CO2 (k) 1.6724 1,767.27 2.98 lb/hr 13.04 tpy 2.98 lb/hr 13.04 tpy Methane 8.4322 8,910.54 15.00 lb/hr 65.72 tpy 0.75 lb/hr 3.29 tpy VOC 71.2810 75,324.65 126.83 lb/hr 555.52 tpy 6.34 lb/hr 27.78 tpy Benzene 0.1605 169.60 0.29 lb/hr 1.251 tpy 0.014 lb/hr 0.063 tpy Toluene 0.1340 141.60 0.24 lb/hr 1.045 tpy 0.012 lb/hr 0.053 tpy Ethylbenzene 0.0073 7.71 0.01 lb/hr 0.057 tpy 0.001 lb/hr 0.003 tpy Xylenes 0.0429 45.33 0.08 lb/hr 0.335 tpy 0.004 lb/hr 0.047 tpy n -Hexane 1.2546 1,325.77 2.23 lb/hr 9.778 tpy 0.112 lb/hr 0.489 tpy 2,2,4-TMP 0.0692 73.13 0.12 lb/hr 0.540 tpy 0.006 lb/hr 0.027 tpy Notes: (a) Annual flow rate is based on 2019 production (b) Based on the weighted average of the low pressure gas analyses (c) Emission factors are from AP -42 Tables 13.5-1 & 2 (Industrial Flares) 40 pg / L is for lightly smoking flare (this is conservative as this unit is smokeless in design). SO2 emissions based on complete conversion of H2S to SO2 (ppm H2S) / (379 scf/Ib-mote) • (1 mole SO2/mole H2S)(64 lb SO2/lb-mole) / (Btu/scf) = lb SO2 / MMBtu N2O emission factor from 40 CFR Part 98 Table C-2 for Natural Gas. (d) Hourly Emission Rate except for PMio and CO2: lb/hr= (Emission Factor, Ib/MMBtu) ' (Heat Input, MMBtu/hr) (e) CO2 lb/hr = (Emission Factor, Ib/MMscf) ` (MMscf/1 if scf)' (Gas Flow Rate, Bahr) (f) lb PM o / hr = (MMscf CH4) (10.6 scf E/scf CH4) (0.0283 m'/scf E) (40 p PMio/L E) (1000 I'm') (g/106 Ng) (lb/453.59 g) / (hr/yr) (g) Annual Emission Rate (tpy) _ (Hourly Emission Rate, lb/hr)" (hr/yr) / (2,000 lb/ton) (h) This represents CO2 as a product of combustion. It is calculated using equation W-21 of 40 CFR Part 98 (i) Emission Factor (Ib/MMscf) _ (MW, lb/lb-mole) / (379 scf/lb-mole) `(consituent weight %) / 100' 1� (I) VOC and HAP emissions: Uncontrolled Controlled (scf/hr) ` (Ib/MMscf) / 10^6 = lb/hr (lb/hr) (100 - DE %) / (100) = lb/hr (lb /hr) (hr/yr) (ton/2,000 lb) = ton/yr (ton/yr) (100 - DE%) / (100) = ton/yr (k) This represents CO2 existing in the fuel gas (uncombusted) Superseded by APEN Addendum received by email on 12/11/2020. JJones - APCD Condensate Storage Tank(s) APEN Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude ail storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 15WE0418 AIRS ID Number: 123 / 9D43 /011 Section 1 - Administrative Information Company Name: Bonanza Creek Energy Operating Company, LLC (BCEOC) Site Name: North Platte A-33 Production Facility (COGCC #438202) Site Location: NWNW, 5N, 33, 63W 40.362217, -104.448806 Mailing Address: (include zip Code) 410 17th Street, Suite 1400 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address2: Alisson Soehner (303) 803-1752 asoehner@bonanzacrk.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 432252 SO COLORADO x•011,cnw Permit Number: 15WE0418 Section 2 - Requested Action AIRS ID Number: 123 /9D43/011 ❑ NEW permit OR newly -reported emission source ❑ Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. - OR 0 MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name3 0 Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) - OR ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Requesting new throughput and emission limits using update emission factors. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. Section 3 - General Information General description of equipment and purpose: Condensate storage tank battery used to store condensate. Company equipment Identification No. (optional): For existing sources, operation began on: CNDTK-01 12/11/2014 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 weeks/year 0 Exploration & Production (E&P) site ❑ Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? Are Flash Emissions anticipated from these storage tanks? Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? 0 Yes No 0 Yes No Yes If "yes", identify the stock tank gas -to -oil ratio: Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes Yes 0 No m3/liter O 0 No No SC COLORADO Domain.. Public NWq b Pnwen�N Permit Number: 15WE0418 AIRS ID Number: 123 /9D43/011 Section 4 - Storage Tank(s) Information Condensate Throughput: Actual Annual Amount (bbUyear) 38,358 Requested Annual Permit limits (bbl/year) 46,030 From what year is the actual annual amount? 2019 Average API gravity of sales oil: 45.5 degrees ❑ Internal floating roof Tank design: ❑ Fixed roof RVP of sales oil: 9.1 El External floating roof Storage Tank ID # of liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) CNDTK-01 Eight (8) 800 bbl 6.400 09/2014 11/2014 Wells Serviced by this Storage Tank or Tank Battery6 (E@P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 39906 North Platte 11-41-33HC ■ 05 - 123 - 39902 North Platte 11-41-33HNB ❑ 05 - 123 - 39905 North Platte A11-U41-33HNC ■ 05 - 123 - 39904 North Platte A-U-33HC ■ 05 - 123 - 39903 North Platte B11-V41-33HNC ■ 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 6 The EEtP Storage Tank APEN Addendum (form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.362217, -104.448806 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) ECD 01-06 —35 500 TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) Q Circular ❑ Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): 48 Interior stack width (inches): Interior stack depth (inches): S. COLORADO Hutfnb lnn,wunn� Permit Number: 15WE0418 AIRS ID Number: 123 /9D43/011 Section 6 - Control Device Information' ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: 054 MMBtu/hr Type: Enclosed Combustion Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 % Minimum Temperature: 500 Six (6) Leed 48" Waste Gas Heat Content: 2,712 Btu/scf Constant Pilot Light: Yes ❑ No Pilot Burner Rating: 0.05 MMBtu/hr Description of the closed loop system: ❑ Closed Loop System ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (Eftp Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? ~50 psig Describe the separation process between the well and the storage tanks: Well is produced to inlet separators where gas, condensate, and water are separated from each other. Condensate is routed to the condensate storage tank battery prior to being trucked from site. INEND,COLORADO Ntahn 6 Gnrmmanl Permit Number: 15WE0418 AIRS ID Number: 123 /9D43/011 Section 8 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? Yes ❑ No If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or combined values if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Description Collection Efficiency (% of total emissions captured by control equipment) Control Efficiency (% reduction of captured emissions) yOC ECD 100 95 NOx CO HAPs ECD 100 95 Other: From what year is the following reported actual annual emissions data? 2019 is pollutant emissions from source: Pollutant Emission Factor? Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions$ (tans/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tonslyear) VOC 5.5286 Ibibbl Permit 13 106.04 5.30 127:25 6-36 NOX 0.068 Ib/MMBtu AP -42 015 0.15 0.17 0.17 CO 0.310 Ib/MMBtu AP -42 0.69 0.69 0.74 074 5 Requested values wilt become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 9 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? Ej Yes ❑ No report the non -criteria pollutant (HAP} emissions from source: Chemical Name Chemical Abstract Service (CAS) Number Emission Factor? Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (lbs/year) Controlled Emissions (lbs/year) Benzene 71432 0.0290 Ib/bbl Permit 13 1.114 56 Toluene 108883 0.0351 Ib/bbl Perrnit 13 1.346 67 Ethylbenzene 100414 0.0020 Ibibbl Permit 13 De Minimis De Min imis Xylene 1330207 0.0133 lb/bbl Permit 13 512 25 n -Hexane 110543 0.2393 Ib/bbl Permit I3 9.178 459 2,2,4-Trimethylpentane 540841 0.0159 lbrobl Permit 13 610 31 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14.03. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. legit .COLOR 0 Oep.ew.emdPm.,rc I HwiU6 Umrmnrne Permit Number: 15WE0418 AIRS ID Number: 123 /9D43/011 Section 10 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. 6/04/2020 Signature of Legally Authorized Person (not a vendor or consultant) Date Alisson Soehner Environmental Engineer, Air Quality Name (print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance Q Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 OR (303) 692-3148 APCD Main Phone Number (303)692-3150 -COLORADO Health fn..mnmmt E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml Company Name: Bonanza Creek Energy Operating Company, LLC Source Name: North Platte A-33 Production Facility (COGCC# 438202) Emissions Source AIRS ID2: 123 / 9BEE / 011 Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 -123 - 39907 North Platte B11-V41-33HNC ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - = ❑ - - ❑ - - ❑ Footnotes: I Attach this addendum to associated APEN form when needed to report additional wells. '- If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 APCD 212_CNDTK 3 .docx COPHE (APEN Addendum received by email on 12/11/2020. JJones - APCD Condensate Storage Tank(s) APEN Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 15WE0418 AIRS ID Number: 123 / 9D43 /011 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Namet: Bonanza Creek Energy Operating Company, LLC (BCEOC) Site Name: North Platte A-33 Production Facility (COGCC #438202) Site Location: NWNW, 5N, 33, 63W 40.362217, -104.448806 Mailing Address: (Include Zip Code) 410 17th Street, Suite 1400 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Addressz: Alisson Soehner (303) 803-1752 asoehner@bonanzacrk.com Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. z Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 07/2020 jetelkif.Oi..OR:D 1 I Hahn b Environment Permit Number: 15WE0418 AIRS ID Number: 123 /9D43/011 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $353.13 must be submitted along with the APEN filing fee. -OR- ✓❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name3 ✓❑ Change permit limit ❑ Transfer of ownership.' ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info It Notes: Requesting new throughput and emission limits using update emission factors. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. .' For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Condensate storage tank battery used to store condensate. CNDTK-01 12/11/2014 For new or reconstructed sources, the projected start-up date is: 24 Normal Hours of Source Operation: Storage tank(s)located at: hours/day 7 ❑✓ Exploration Et Production (EEIP) site days/week 52 weeks/year ❑ Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? 12 Yes ■ No Are Flash Emissions anticipated from these storage tanks? l7 Yes ■ No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? ■ Yes SI No If "yes", identify the stock tank gas -to -oil ratio: m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)• 805 series rules? If so, submit Form APCD-105. Yes No SI Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual• emissions a 6 ton/yr (per storage tank)? Yes No BI Form APCD-205 Condensate Storage Tank(s) APEN - Revision 07/2020 (COLORADO 2igel Department w Amm ✓❑ Upward ❑ Horizontal Permit Number: 15WE0418 AIRS ID Number: 123 /9D43/011 [Leave blank unless APCD has already assigned a permit Y and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbUyear) ` Requested Annual Permit Limits (bbllyeirr) ' Condensate Throughput: 38,358 46,030 From what year is the actual annual amount? 2019 Average API gravity of sales oil: 45.5 degrees ❑ Internal floating roof Tank design: ❑✓ Fixed roof RVP of sales oil: 9.1 ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels In Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in s" Storage Tank (nronthlyear) Date of First Production (1ror►th/year) CNDTK-01 Eight (8) 800 bbl 6,400 09/2014 11/2014 Wells Serviced b this Storage Tank or Tank Batte by g ryb (IftP Sites OrfIY) API Number Name of Well Newly Reported Well 05 - 123 - 39906 North Platte 11-41-33HC 05 - 123 - 39902 North Platte 11-41-33HNB • 05 - 123 - 39905 North Platte All-U41-33HNC • 05 - 123 - 39904 North Platte A-U-33HC MI 05 - 123 - 39903 North Platte B11-V41-33HNC • 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 6 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Lonsitude or UTM) 40.362217, -104.448806 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stacic ; ID No. Discharge Height Above Ground Level (Feet) Temp. ('F) Flow Rate (ACFM) Velocity (ft%sec) ECD 01-06 —35 500 TB TB Indicate the direction of the stack outlet: (check one) ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ✓❑ Circular ❑ Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): 48 Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2020 COLORADO 3 I I H°"tnb Envtonnsomt Permit Number: 15WE0418 AIRS ID Number: 123 /9D43/011 [Leave blank unless APCD has already assigned a permit x and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: 1.03 MMBtu/hr Type: Enclosed Combustor Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 95 Minimum Temperature: 500 Six (6) Leed 48" Waste Gas Heat Content: 2,712 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 0.05 MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (MP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —50 Describe the separation process between the well and the storage tanks: psig Well is produced to inlet separators where gas, condensate, and water are separated from each other. Condensate is routed to the condensate storage tank battery prior to being trucked from site. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2020 COLORADO butt. Etrvnnntnent Benzene Permit Number: 15WE0418 AIRS ID Number: 123 /9D43/011 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form7. Is any emission control equipment or practice used to reduce emissions? ❑ Yes ❑ No If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): VOC NOX CO HAPs Other: Control Equipment Description ECD Overall Requested Control Efficiency (% reduction in emrssrons) 95 ECD 95 From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source: Pollutant' VOC NO. CO Uncontrolled Basis 5.5288 Ib/bbl Source (AP -42, Mfg., etc.) Permit 13 Actual Annual Emissions Uncontrolled Emissions (tons/year) 106.04 Controlled Emissions$ (tons/year) 0.068 0.310 Ib/MMBtu Ib/MMBtu AP -42 AP -42 0.28 1.24 5.30 0.28 1.24 Requested Annual Permit Emission liinit(s)5 Uncontrolled Emissions (tons/year), 127.25 0.31 Controlled Emissions (tons/year) 1.40 6.36 0.31 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. 1.40 Section 9 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? E✓ Yes ❑ No If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: Chemical Abstract Service (CAS) Number Toluene Ethylbenzene Xylene n -Hexane 2, 2,4-Trimethylpentane 71432 108883 100414 Emission Factor? Uncontrolled Basis 0.0290 0.0351 lb/bbl Source. (AP -42, Mfg., etc.) Actua[ Annual Emissions Uncontrolled Emissions (tbs/year) lb/bbl Permit 13 Permit 13 1330207 110543 540841 0.0020 lb/bbl Permit 13 0.0133 lb/bbl Permit 13 1,114 1,346 56 De Minimis 0.2393 lb/bbl Permit13 0.0159 lb/bbl Permit 13 512 67 De Minimis 9,178 610 26 459 31 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Form APCD-205 Condensate Storage Tank(s) ADEN - Revision 07/2020 !cot.oRAoo 5 ( a+vim Permit Number: 15WE0418 AIRS ID Number: 123 /9D43/011 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 10 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signature of Legally Authorized Person (not a vendor or consultant) Date Alisson Soehner Environmental Engineer, Air Quality Name (print) Title Check the appropriate box to request a copy of the: �✓ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $216.00 and the General For more information or assistance call: Permit registration fee of $353.13, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Small Business Assistance Program (303) 692-3175 OR (303)692-3148 APCD Main Phone Number (303)692-3150 Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2020 lcOLORADO Department al Public I Health 6 Environment 12/15/2020 State.co.us Executive Branch Mail - BCEOC North Platte A-33 syn-minor application STATE OF COLORADO Jones - CDPHE, Joshua <joshua.jones@state.co.us> BCEOC North Platte A-33 syn-minor application Patrick Di!saver <PDilsaver@bonanzacrk.com> Thu, Dec 10, 2020 at 10:32 AM To: "Jones - CDPHE, Joshua" <joshua.jones@state.co.us>, "pdilsaver@slrconsulting.com" <pdilsaver@slrconsulting.com> Cc: Alisson Soehner <ASoehner@bonanzacrk.com> Hey Josh, I just copied responses below and have several attachments. Let us know your thoughts and we will work to get anything out by the deadline! LPGFL (point 007) 1. In the previous issuance of 15WE0418, BCEOC requested the reference to the Vapor Recovery Tower (VRT) to remain in the description for this point in the permit to keep open the option of returning the VRT to service. Is the VRT still at this facility and does BCEOC want to keep the option to operate it? If so, emissions calculations should be revised according to the EFs from the previous issuance, which incorporate emissions from the LP separators as well as the VRT. The VRT is still onsite but not in use. We always prefer to keep operational flexibility if possible, so we would like to keep the option. I attached a revised calculation sheet which I believe reverts back to the emission factors that included VRT from Issuance 2. I had to revise the permitted flow rate to keep permitted emissions relatively the same. If this is acceptable we can provide redlines or a "clean" APEN if that is helpful. Let us know your thoughts. 2. The O&M plan for separator flaring needs to be revised according to language in the version recently accepted by the Division. My reference given for this is the O&M plan for point 010 at the Antelope P-17 production facility (12WE2919 / 123-9A53). This includes the addition in Section 4 — Monitoring Requirements of the method for determining the volume of separator gas using a calculated ratio of separator gas to total gas based on flash factors and applying it to the measured total when a negative flowrate is calculated by standard methods. This is in place of the flow to the separator being assumed to be zero. This also includes removal of last paragraph that begins "In the event the flow meter data is missing or invalid...". Because the permit requires a flow meter to monitor separator gas flared, this would seem to offer a means of alternative compliance, which is not the intent of the O&M plan. If you would please revise the O&M plan for point 007 and send it to me. Revised and attached. CNDTK-01 (point 011 3. NOX and CO emissions for the condensate tank battery are calculated based on a waste gas flow of 16.97 scf/bbl. Can you verify for me where this value came from? I calculated a value of 49.00 scf/bbl based on results of the ProMax model run submitted in the application for Issuance 3 (0.0445915 MMscfd Tank Losses, 910 bbl/day Sales Oil). Also, the waste gas heat content was estimated at 2712 Btu/scf HHV. This seems to be from the ProMax model run results provided in the application for the initial issuance. A heat content of 2796 Btu/scf is given in the model run for Issuance 3. I believe NOX and CO emissions should be calculated using waste gas values from the model used to calculate the VOC emission factor. I got NOX at about 0.31 tpy and CO at 1.4 tpy including pilot light emissions. https://mail.google.com/mail/u/Vik=6fb81 abf08&view=pt&search=all&permmsgid=msg-f%3A 1685713372936728081 &simpl=msg-f%3A 168571337293... 1/2 12/15/2020 State.co.us Executive Branch Mail - BCEOC North Platte A-33 syn-minor application Please let me know if you agree. If you agree, can you please submit a revised calculation sheet and I can red -line the APENs and provide BCEOC with copies. I agree with this, revised calculations attached. 4. In the O&M plan provided for the condensate tank, in Section 4 — Monitoring Requirements, the check box is marked indicating that these tanks are not subject to the STEM requirements of Reg. 7, Section XVII.C.2 and C.3 (now Part D, Section II.C.2 and II.C.3). It seems these tanks are subject to STEM requirements, so, with your approval, I will red -line the O&M plan to check the box saying they are subject and send a copy for BCEOC's records. Yes, these tanks should be subject to STEM, we will keep the redlined O&M for our records, thanks! From: Jones - CDPHE, Joshua[mailto:joshua.jones@state.co.us] Sent: Tuesday, December 08, 2020 4:29 PM To: Patrick Dilsaver <PDilsaver@bonanzacrk,com>; pdilsaver@slrconsulting.com Cc: Alisson Soehner <ASoehner@bonanzacrk.com> Subject: [EXTERNAL] BCEOC North Platte A-33 syn-minor application External Sender: Use caution with links/attachments [Quoted text hidden] 3 attachments _SEP OM.pdf 70K Copy of North Platte A-33 Emissions 20200602_CNDTKRedlines.pdf 17K tin NP A-33 LPGFL_VRT Calc Redlines 20201210 .pdf 72K https://mail.google.com/mail/u/0?ik=6fb81 abf08&view=pt&search=all&permmsgid=msg-f%3A1685713372936728081 &simpl=msg-f%3A168571337293... 2/2 12/15/2020 State.co.us Executive Branch Mail - BCEOC North Platte A-33 syn-minor application STATE OF COLORADO Jones - CDPHE, Joshua <joshua.jones@state.co.us> BCEOC North Platte A-33 syn-minor application Leah Althoff <lalthoff@slrconsulting.com> _ To: "Jones - CDPHE, Joshua" <joshua.jones@state.co.us>, Patrick Dilsaver <pdilsaver@slrconsultingi.com>11, 2020 at 12:02 PM Cc: Patrick Dilsaver <PDilsaver@bonanzacrk.com>, Alisson Soehner <asoehner@bonanzacrk.com> Hi Josh, Please find the updated APENs for the CNDTK and LPGFL attached. Thanks! SLR Leah Althoff 970-999-3978 =a 970-494-0805 612-770-3941 lalthoff@slrconsulting.com SLR International Corporation 1612 Specht Point Road, Suite 119, Fort Collins, CO 80525 Confidentiality Notice and Disclaimer This communication and any attachment(s) contain information which is confidential and may also be legally privileged. It is intended for the exclusive use of the recipient(s) to whom it is addressed. If you have received this communication in error, please e-mail us by return e-mail and then delete the e-mail from your system together with any copies of it. Any views or opinions are solely those of the author and do not represent those of SLR Management Ltd, or any of its subsidiaries, unless specifically stated. From: Jones - CDPHE, Joshua <joshua.jones@state.co.us> Sent: December 11, 2020 8:44 AM To: Patrick Dilsaver <pdilsaver@slrconsulting.com> Cc: Patrick Dilsaver <PDilsaver@bonanzacrk.com>; Alisson Soehner <asoehner@bonanzacrk.com>; Leah Althoff <lalthoff@slrconsulting.com> Subject: Re: FW: [EXTERNAL] BCEOC North Platte A-33 syn-minor application [Quoted text hidden] 2 attachments APEN 205_20201211.pdf 306K APEN 211_20201211.pdf 281K https://mail.google. com/mail/u/0?ik=6fb81 abf08&view=pt&search=all&permmsgid=msg-f%3A1685809641458252847&simpl=msg-f%3A168580964145... 1/1 Bonanza Creek Energy Operating Company, LLC. - North Platte A-33 Production Facility (COGCC #438202) Condensate Tank Site Specific Emission Factor Calculations Emission Source: Condensate Tanks Requested Throughput: 46,030 bbl/yr Enclosed Flare VOC Control Efficiency: 95% Operating Days per Year: 365 days/yr Designed Throughput: 105 bbl/day Designed Throughput: 38,358 bbl/yr Total Emissions Pollutant CO2 Methane VOC Benzene Toluene Emission Factors (') (lb/bbl) 0.0464 Actual Emissions (tpy) (d) Uncontrolled 0.89 Controlled 0.04 Requested Emissions (tpy) (a Uncontrolled 1.07 Controlled 0.1044 5.5288 2.00 106.04 0 10 5.30 Ethylbenzene Xylenes n -Hexane 224-TMP 0.0290 0.0351 0.0020 00133 0.2393 0.0159 0.56 0.67 0.04 0.26 4.59 0.31 0.03 0.03 0.00 0.01 0.23 0 02 2.40 127.25 0.67 0.81 0.05 0.31 5.51 0.37 0.05 0.12 6.36 0.03 0.04 0.00 0.02 028 0 02 Notes: (a) Emission Factors from Permit 15VVE0418 Issuance 3 (b) Potential to Emit (tpy) _ (Emission Factor, lb/bbl) • (PTE Throughput, bbVyr) / (2,000 lb/ton) (c) Requested Emissions (tpy) _ (Actual Emissions, tpy) • 1.2 (d) Uncontrolled Emissions (tpy) _ (Emission Factor, Ib/bb0 • (Actual Throughput, bbl/yr) / (2,000 lb/ton) Bonanza Creek Energy Operating Company, LLC. - North Platte A-33 Production Facility (COGCC #438202) Enclosed Combustion Device (ECD) Emission Calculations for Condensate Tank Battery 1 Emission Source: Condensate Tanks Source Type: ECD Heat Input Requested: 1.03 MMBtu/hr Heat Input Actual: 0.91 MMBtu/hr Gas Oil Ratio (GOR): 49.00 scf/bbl Tank Vent Gas Flowrate Requested: 257.5 scf/hr Tank Vent Gas Flowrate Requested: 2.26 MMscf/y_r Tank Vent Gas Flowrate Actual: 214.6 scf/hr Tank Vent Gas Flowrate Actual: 1.88 MMscf/yr Pilot Gas Flowrate: 18.5 scf/hr Pilot Gas Flowrate: 0.16 MMscf/yr Total Combustors: 6 Total Flowrate to Combustor Including Pilot: 2.85 MMscf/yr Estimated HHV: 2,796 Btu/scf Total VOC Control Efficiency: _95% Sulfur Content of Fuel: 0.0020 gr/scf Operating Hours per Year: 8,760 hr/yr Pollutant CO2 N20 NO CO SO2 PM10 PM2.5 Emission Factors or Uncontrolled Emissions (') Actual Emissions lb/hr 116.98 Ib/MMBtu 0.00030 Ib/MMBtu 0.068 Ib/MMBtu 0.310 Ib/MMBtu 0.00030 Ib/MMBtu 40.0 u9 / [ 40.0 pg / t 106.48 0.00 0.06 0.28 0.0003 0.0062 0.0062 tpy (d) 466.39 0.01 0.28 1.24 0.0012 0.0271 0.0271 Requested Emissions lb/hr (b).(`) 120.52 0.00 0.07 0.32 0.0003 0.0073 0.0073 Notes: (a) Emission factors are from AP -42 Tables 13.5-1 8 2 (Industrial Flares) 40 pg / L is for lightly smoking flare (this is conservative as this unit is smokeless in design). SOz emissions based on AP42, which is based on 100% conversion of sulfur to SO z at 2000 grains/MMscf. CO2 and N2O emission factors from 40 CFR Part 98 Table C-1 and C-2 for Natural Gas. (b) Hourly Emission Rate (lb/hr) except for PM,, = (Emission Factor, Ib/MMBtu) • (Heat Input, MMI3tu/hr) (c) (scf CH,,/hr) (10.6 scf E/scf CHa) (0.0283 m'/scf E) (40 p PM,o/L E) (1000 I/ms) (9/10e pg) (lb/453.59 g) / (hr/yr) = lb PM,a / hr (d) Annual Emission Rate (tpy) _ (Hourly Emission Rate, Ib/hr) • (hr/yr) / (2,000 lb/ton) tpy (d) 527.87 0.01 0.31 1.40 0.0014 0.0320 0.0320 Hydrocarbon Liquid Loading APEN Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 15WE0418 AIRS ID Number: 123 / 9D43 /012 Section 1 - Administrative Information Company Name1: Bonanza Creek Energy Operating Company, LLC (BCEOC) Site Name: North Platte A-33 Production Facility (COGCC #438202) Site Location Site Location: NWNW, 5N, 33, 63W County: Weld 40.362217, -104.448806 Mailing Address: (Include Zip Code) 410 17th Street, Suite 1400 Denver, CO 80202 NAICS or SIC Code: 1311 Contact Person: Alisson SOehner Phone Number: (303) 803-1752 E -Mail Address2: asoehner@bonanzacrk.com t Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 432263 IROCOLORDep.= ADO apx.nwne,neuc w..nn�rn�.mmem Permit Number: 15WE0418 AIRS ID Number: 123 /9D43/012 Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source ❑ Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- Q MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info ii Notes: Requesting new throughput and emission limits using state factors. Updating collection efficiency from 70% to 100°/x. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Truck loadout used to truck condensate from site. Company equipment Identification No. (optional): L-01 For existing sources, operation began on: 12/11/2014 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? Yes No O ■ Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No ■ p Does this source load gasoline into transport vehicles? ❑ Yes No SI Is this source located at an oil and gas exploration and production site? Yes No El ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No 0 ■ Does this source splash fill less than 6,750 bbl of condensate per year? Yes No GI ■ Does this source submerge fill less than 16,308. bbl of condensate per year? Yes No ■ 0 a®COLORA00 MMaE �wyn�inw1 Permit Number: 15WE0418 AIRS ID Number: 123 /9D43/012 Section 4 - Process Equipment Information Product Loaded: ❑✓ Condensate ❑ Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 46,030 bbl/year Actual Volume Loaded: This product is loaded from tanks at this facility into: tank trucks (e.g. "rail tank cars" or "tank trucks") 46,030 bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: Average temperature of bulk liquid loading: F True Vapor Pressure: Psia @ 60 `F Molecular weight of displaced vapors: lb/lb-mot If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft' Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft' /truckload 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.362217,-104.448806 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. ('F) Flow Rate (ACFM) Velocity (ft/sec) ECD 01-06 -35 500 TBD TBD Indicate the direction of the stack outlet: (check one) 0 Upward ❑ Horizontal ❑ Downward ❑ Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) ® Circular Interior stack diameter (inches): 48 ❑ Square/rectangle Interior stack width (inches): ❑ Other (describe): Interior stack depth (inches): COLORADO d.n.nmwu Na1M a Wrtrmm. Permit Number: 15WE0418 AIRS ID Number: 123 /9D43/012 Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Q Loading occurs using a vapor balance system: Requested Control Efficiency: 100 % 0 Combustion Device: Used for control of: VOC, HAPs Rating: 0.03 Type: Requested Manufacturer Guaranteed Minimum Temperature: Constant Pilot Light: M/OBtu/hr Enclosed Combustor Make/Model: Control Efficiency: 95 % Control Efficiency: 98 % 500 `F Waste Gas Heat Content: ❑ Yes El No Pilot Burner Rating: Six (6) Leed 48" 3,153 Btu / scf N/A MMBtu/hr ❑ Other: Pollutants Controlled: Description: Requested Control Efficiency: Section 7 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? Yes ❑ No If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or combined, values if multiple emission control methods were 'f' d ',ICI... (] Using State Emission Factors (Required for GP07) Condensate ❑ Crude VOC 0.236 Lbs/BBL 0.104 Lbs/BBL Benzene 0.00041 Lbs/BBL 0.00018 Lbs/BBL From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria n -Hexane 0.0036 Lbs/BBL 0.0016 Lbs/BBL r_____, ---...........c. Emission Factor Actual Annual Emissions Requested Annual Permit Pollutant Emission Limit(s)5 Uncontrolled Units Source (AP -42, Uncontrolled Controlled Uncontrolled Controlled Basis Mfg., etc.) Emissions (tons/year) Emissions6 (tons/year) Emissions (tons/ ear Y ) Emissions (tans/year) PM 40 .0 ug/L AP -42 0.001 0.001 0.001 0.001 SOx 0.00018 Ib/MMBtu AP -42 <0.001 <0.001 <0.001 <0.001 NO), 0.068 Ib/MMBtu AP -42 0.009 0.009 0.009 0,009 CO 0.310 Ib/MMBtu AP -42 0.041 0.041 0' 41 0.041 VOC 0.236 lb/bbl State EF 5 45 0.28 5. .45 0.28 5 Requested values wilt become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. ®...COLORADO .1 DepartmentaMtlic atalm�YNitnw.mwN Permit Number: 15WE0418 AIRS ID Number: 123 /9D43/012 Section 8 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? If yes, use the following table to report the non criteria pollutant (HAP) emissions from sou• ❑ Yes li No Chemical Name Chemical Abstract Service(CAS)Uncontrolled. Number Emission Factor rce. Actual Annual Emissions Basis Units Source (.4P-42, Mfg., etc.) Uncontrolled Emissions (lbs/year) Controlled Emissionsb abs/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2,2,4-Trimethylpentane 540841 Other: 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. 72l�- 6/4/2020 Signature of Legally Authorized Person (not a vendor or consultant) Date Alisson Soehner Name (print) Environmental Engineer, Air Quality Title Check the appropriate box to request a copy of the: Draft permit prior to issuance [li Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303)692-3175 OR (303)692-3148 APCD Main Phone Number (303) 692-3150 COLORAD MOP NOP• O En o' nme xarx emn.��n Hello