HomeMy WebLinkAbout20203839.tiffa„,xY
COLORADO
Department of Public
Health 8 Environment
Weld County - Clerk to the Board
1150 O St
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 - State Antelope P-16 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.colorado.gov/cdphe If -Q`
Jared Polis, Governor I Jill Hunsaker Ryan, MPH, Executive Director I �, 1O1
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Pub -,c Re. v;ew
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12 /2q /20
2020-3839
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Bonanza Creek Energy Operating Company, LLC - State Antelope P-16 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: State Antelope P-16 Production Facility
Well production facility
NENW Section 16 T5N R62W
Weld County
The proposed project or activity is as follows: The applicant proposes to decrease throughput through the
condensate tanks and hydrocarbon liquids loadout and lower the emission limits on these tanks.
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 14WE0196 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:
Jaclyn Zey
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
Department of Public
Health 6 Environment
COLORADO
Air Pollution Control Division
Der.ort,ent ot Public H- al.h b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
14WE0196
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
Issuance: 3
Bonanza Creek Energy Operating Company, LLC
State Antelope P-16 Production Facility
123/96DD
NENW Section 16 T5N R62W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
CND 01
002
Six (6) 500 barrel fixed roof storage vessels
used to store condensate.
Enclosed Flare
L-01
004
Truck loadout of condensate by submerged fill.
No control
SEP 1 and
SEP-2
006
Two (2) low pressure separators.
Enclosed Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and
the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the 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 shall not exceed the following limitations. (Regulation Number 3, Part B,
Section II.A.4.)
AIRS ID: 123 96DD Page 1 of 12
COLORADO
Air Pollution Control Division
Department of PL,Ulc Hea€:h Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO„
VOC
CO
CND -01
002
---
---
0.4
---
Point
L-01
004
---
---
3.0
---
Point
SEP-1 and SEP-2
006
---
---
18.9
4.9
Point
lote: See "Notes to Permit Holder" for information on emission factors and methods used to cal
limits.
culate
Compliance with the annual limits for criteria pollutants shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve month total is calculated based on the previous
twelve months' data. The permit holder shall calculate 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 shall 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.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutant's
Controlled
CND -01
002
Enclosed Flares
(Four (4) LEED L30-0010-000)
VOC and HAP
SEP-1 and
SEP-2
006
Enclosed Flares
(Four (4) LEED L30-0010-000)
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
5. This source shall 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:
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
CND -01
002
Condensate throughput
25,331 barrels
L-01
004
Condensate loaded
25,331 barrels
AIRS ID: 123 96DD
Page 2 of 12
COLORADO
Air Pollution Control Division
Dep8rtrrent or Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
SEP 1 and
SEP-2
006
Natural gas venting
13.2 MMscf
The owner or operator shall monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total.
By the end of each month a new twelve-month total is calculated based on the previous twelve months'
data. The permit holder shall calculate throughput each month and keep a compliance record on site or
at a local field office with site responsibility, for Division review.
6. Point 006: The owner or operator shall continuously monitor and record the volumetric flow rate of
natural gas vented from the low pressure separators using the flow meter. The owner or operator shall
use monthly throughput records 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. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/9BDD/xxx) 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)
9. Point 006: No owner or operator of a smokeless flare or other flare for the combustion of waste gases
shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity
for a period or periods aggregating more than six minutes in any consecutive minutes. (Reference:
Regulation No. 1, Section II.A.5)
10. Point 002: This source is subject to Regulation Number 7, Part D, Section I. The operator shall comply
with all applicable requirements of Section I and, specifically, shall:
• Comply with the recordkeeping, monitoring, reporting and emission control requirements for
condensate storage tanks
• Ensure that all hydrocarbon liquids and produced water collection, storage, processing, and
handling operations, regardless of size, must be designed, operated, and maintained so as to
minimize emissions of volatile organic compounds to the atmosphere to the maximum extent
practicable. (Regulation Number 7, Part D, Section I.C.); 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.) (State
only enforceable)
11. Point 002: The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used
to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have
no visible emissions during normal operations, as defined under Regulation Number 7, Part D, II.A.23;
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 flare must be equipped with an operational auto -igniter according to the
schedule in Regulation Number 7, Part D, Section II.B.2.d.
12. Point 002: The storage tank covered by this permit is 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
AIRS ID: 123 9BDD Page 3 of 12
COLORADO
Air Pollution Control Division
Department of Public Health v Environmenr
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
13. Point 002: 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.
14. Point 004: This source is located in an ozone non -attainment or attainment -maintenance area and is
subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3,
Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference:
Regulation 3, Part B, III.E)
15. Point 004: All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and
maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum
extent practicable.
16. Point 004: The owner or operator shall follow loading procedures that minimize the leakage of VOCs to
the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.E):
a. The owner or operator shall inspect onsite loading equipment to ensure that hoses, couplings,
and valves are maintained to prevent dripping, leaking,. or other liquid or vapor loss during
loading and unloading. The inspections shall occur at least monthly. Each inspection shall be
documented in a log available to the Division on request.
b. All compartment hatches at the facility (including thief hatches) shall be closed and latched at
all times when loading operations are not active, except for periods of maintenance, gauging, or
safety of personnel and equipment.
c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall
be weighted and properly seated.
d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary.
PRDs shall be set to release at a pressure that will ensure flashing, working and breathing losses
are not vented through the PRD under normal operating conditions.
e. Document annual inspections of thief hatch seals and PRD with an indication of status, a
description of any problems found, and their resolution.
17. Point 004: Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled as
outlined in Regulation Number 7, Part D, Section II.C.5.a. by using (a) submerged 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 with the following schedule: (Regulation Number 7, Part D, Section
II.C.5.a.)
• 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
AIRS ID: 123 9BDD Page 4 of 12
COLORADO
Air Pollution Control Division
Department r tu bl:c HeaiU.. Environmenz
Dedicated to protecting and improving the health and environment of the people of Colorado
year on a rolling 12 -month basis must control emissions from loadout upon exceeding the loadout
threshold.
18. Point 004: Storage tanks must operate without venting at all times during loadout. (Regulation Number
7, Part D, Section II.C.5.a.(ii))
19. Point 004: The owner or operator must, as applicable (Regulation Number 7, Part D, Section II.C.5.a.(iii)):
• 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 liquids or vapor loss during
loadout. These inspections must occur at least monthly, unless loadout occurs less frequently,
then as often as loadout is occurring.
20. Point 004: The owner or operator must perform the following observations and training (Regulation
Number 7, Part D, Section II.C.5.a.(iv)):
• 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.
• 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 from 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.
21. Point 004: 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.
• 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 II.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.
AIRS ID: 123 9BDD Page 5 of 12
;COLORADO
Air Pollution Control Division
l Department of PL,bile Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• Records of the annual training program, including the date and names of persons trained.
22. Point 004: Air pollution control 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))
23. The requirements of Colorado Regulation No. 3, Part D must 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, VI.B.4/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:
Facility
Equipment
ID
AIRS
Point
Equipment
Descrion ti
P
Pollutant
Emissions - tons per year
Threshold
Current
Permit
Limit
CND 01
002
Condensate
Storage Tanks
V0C
50
22.3
L-01
004
Truck
Loadout
SEP 1 and
SEP-2
006
Low Pressure
Separators
OPERATING Et MAINTENANCE REQUIREMENTS
25. Points 002 and 006: The owner or operator shall follow the most recent operating and maintenance
(O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on
an ongoing basis with the requirements of this permit. Revisions to the OEtM 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
26. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other
state or federal requirement.
ADDITIONAL REQUIREMENTS
27. All previous versions of this permit are cancelled upon issuance of this permit.
28. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons
per year or more, above the level reported on the last APEN; or
AIRS ID: 123 96DD Page 6 of 12
COLORADO
Air Pollution Control Division
Cepartm t r b:1.e Health 8 EMITu. MCffit
Dedicated to protecting and improving the health and environment of the people of Colorado
For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone nonattainment
areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions
of one (1) ton per year or more or five percent, whichever is greater, above the level reported
on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five percent or
50 tons per year or more, whichever is less, above the level reported on the last APEN submitted;
or
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
• 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.
29. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time
that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation
that increases the potential to emit above the applicable Federal program threshold will require a full
review of the source as though construction had not yet commenced on the source. The source shall not
exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
30. 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.
31. If this permit specifically states that final authorization has been granted, then the remainder of this
condition is not applicable.Otherwise, the issuance of this construction permit does not provide "final"
authority for this activity or operation of this source. Final authorization of the permit must be secured
from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC
Regulation 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.
32. 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.
AIRS ID: 123 9BDD Page 7 of 12
(COLORADO
Air Pollution Control Division
D.,=p .rtr rent of PL, ;e Heaith 7 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
33. 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.
34. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to
or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such
occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior
to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set
forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission
(AQCC), including failure to meet any express term or condition of the permit. If the Division denies a
permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes
a permit, the owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
35. 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.
36. 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:
Jaclyn Zey
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
April 7, 2015
Issued to Bonanza Creek Energy Operating Company, LLC.
Issuance 2
March 6, 2019
Issued to Bonanza Creek Energy Operating Company, LLC.
Hydrocarbon liquid stored and loaded is changed from crude
oil to condensate. Removed cancelled points 003, 005, 007,
and 008. No changes to emission or throughput limits for
points 002, 004, 006.
Issuance 3
This Issuance
Points 002 a 004: Revised permitted emissions and
throughputs based on APEN received July 1, 2020.
Throughout permit: Updated Colorado Regulation No. 7,
language and citations to version adopted September 23,
2020.
AIRS ID: 123 9BDD
Page 8 of 12
COLORADO
Air Pollution Control Division
Department t Health & Environmem
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 shall 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 shall notify the Division of any malfunction
condition which causes a violation of any emission limit or limits stated in this permit as soon as possible,
but no later than noon of the next working day, followed by written notice to the Division addressing all of
the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:
https://www.colorado.gov/pacific/cdphe/aqcc-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 Division's analysis of the
specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
002
Benzene
71432
127
6
Toluene
108883
76
4
Ethylbenzene
100414
5
0
Xylenes
1330207
10
0
n -Hexane
110543
811
41
2,2,4-
Trimethylpentane
540841
25
1
004
Benzene
71432
10
N/A - Not
Controlled
Toluene
108883
221
Ethylbenzene
100414
44
Xylenes
1330207
148
n -Hexane
110543
91
2,2,4-
Trimethylpentane
540841
66
006
Benzene
71432
795
40
Toluene
108883
435
22
Ethylbenzene
100414
45
2
AIRS ID: 123 9BDD
Page 9 of 12
'COLORADO
Air Pollution Control Division
Department or Pubhc Health 6 Ewer meet
Dedicated to protecting and improving the health and environment of the people of Colorado
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(Ib/yr)
Xylenes
1330207
148
7
n -Hexane
110543
4659
233
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 002:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
NOx
0.0013
0.0013
AP -42 Ch. 13.5
CO
0.0061 ''
0.0061
VOC
0.59
0,03
EEtP TANK model
based on a site -
specific liquid
sample.
71432
Benzene
0.005
0.0003
108883
Toluene
0.003
0.0002
100414
Ethylbenzene
0.0002
0.00001
1330207
Xylene
0.0004
0.00002
110543
n -Hexane
0.032 '
0.0016
540841
2,2,4-
Trimethylpentane
0.001
0.0001
Note: Controlled emissions factors are based on the flare control efficiency of 95%. NOx and CO emission
factors are based on a gas heat value of 2225 Btu/scf.
Point 004:
Pollutant
CAS #
Uncontrolled
Emission Factors'"
lb/bbl
Controlled
Emission
Factors lb/bbl
Source
VOC
0.236
N/A - Not
Controlled
State EF -
Condensate
Loadout
Benzene
71432
0.00041
n -Hexane
110543
0.0036
State EF -
Condensate
Loadout
Point 006:
CAS #
Pollutant
Uncontrolled
Emission Factors
Ib/MMscf
Controlled
Emission Factors
lb/MMscf
Source
NOx
136.68
136.68
AP -42 Ch. 13.5
CO
743.70
743.70
VOC
57163.53
2858.1765
Mass balance on
site -specific
71432
Benzene
59.9813
2.9991
AIRS ID: 123 9BDD
Page 10 of 12
COLORADO
Air Pollution Control Division
Dedicated to protecting and improving the health and environment of the people of Colorado
CAS #
Pollutant
Uncontrolled
Emission Factors
Ib/MMscf
Controlled
Emission Factors
lb/MMscf
Source
extended gas
analysis
108883
Toluene
32.8239
1.6412
100414
Ethylbenzene
3.3616
0.1681
1330207
Xylene
11.2053
0.5603
110543
n -Hexane
351.7
17.5850
Note: Controlled emissions factors are based on the flare control efficiency of 95%. NOx and CO emission
factors are based on a gas heat value of 2010 Btu/scf.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit
is valid for a term of five years from the date it was received by the Division. A revised APEN shall be
submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual
fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For
any questions regarding a specific expiration date call the Division at (303)-692-3150.
7) Point 002: This permit fulfills the requirement to hold a valid permit reflecting the storage tank and
associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC
NANSR
Synthetic Minor Source of: VOC
PSD
Synthetic Minor Source of: VOC
MACT HH
Area Source Requirements: Not Applicable
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A -Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
AIRS ID: 123 96DD
Page 11 of 12
COLORADO
Air Pollution Control Division
Department ,t P_abla: Health El Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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
AIRS ID: 123 96DD Page 12 of 12
ado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
For Division Use Only
Review Engineer:
Package #:
Received Date:
Review Start Date:
Jaclyn Zey
432989
W1/2020
10/1572020
Section 01- Facility Information
Company Name: Bonanza Creek Energy Operating Company. L
County AIRS ID: 123
Plant AIRS ID: SBDD
Facility Name: State Antelope P-16 Productien Facility
Physical _ _...........
Address/Location:��t
County:
Type of Facility:
What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes
If yes, for what pollutant?
Weld County
Exploration & Produeiti°: Wefi Pad
Section 02 - Emissions Units In Permit Application
Ozone (NOx & VOC)
Quadrant
Section
Township
Range
NEW,'
16
Leave Blank - For Division Use Only
AIRS Point #
(Leave blank unless APCD
has already assigned)
Emissions Source Type
Equipment Name
Emissions
Control?
Permit If
(Leave blank unless
APCD has already
assigned)
Issuance
If
Self Cert
Required?
Action
Engineering
Remarks
002
- -
Storage Tank
CND -01
Yes
14WE0196
3
No
f'eCrLk2t -
Pvlodificatan
004
.
Liquid Loading .
#31
No
4WE0196
3. :
No
' Permit
Su1odif€cation
Section 03 - Description of Project
This modification permits new emission ar d throughput limits far the condensate tanks (AIRS tD 002) and liquids laadout (AIRS ID 004) n adoltian: the following
changes were made to the permit:
1. Updated Colorado Regulation Number 7 language throughout permit to be consistenet with recently issued permits and to reflect the version of the rule adopted
on September 23, 2020.
2. Included Colorado Regulation Number
ection V for 'feat ty-guide inventory requ:remerits. Section V requiremnets did not exist during the previous
Sections 04, 05 & 06 - For Division Use Only
Section 04- Public Comment Requirements
Is Public Comment Required?-
Ifyes,why? Requesting Synthetic Miner Permit
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes, 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?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants: SO2
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non-Attairment New Source Review (NANSR)
Is this stationary source a major source?
If yes, indicate programs and which pollutants: SO2
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
NOx
NOx
—
Yes
CO
VOC
VOC
,�
PM2.5 PM10 TSP
J
J
PM2.5 PM10 TSP
HAPs
HAPs
Storage Tankts) Emissions Inventory
Pollutant
Section 01 -Administrative Information
Facility AIRS ID:
County
9800
Plant
CCM
Point
Section 02 - Equipment Description Details
Storage Tank Liquid
Detailed Emissions Unit 5ix(K)500beret fixedmotstorage vessels used to store condensate
Description:
Emission Control Device EricPozeditate'
Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions -Storage Tanks)
Actual Throughput=
Requested Permit Limit Throughput=
5,066.0 Barrels (bbl) per year
25,331.0 Barrels (bbl) per year
Requested Monthly Throughput=
2161 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 e
Requested heat content of waste gas routed to combustion device =
25,331,0 Barrels (bbl) per year
2225.0 Btu/scf
3.3 scf/bbl
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Control Device
from previous permit PA; 3.83 scf/bbl and 16.3 scf/hr pilot
30 5 MMBTU per year
437 MMBTU per year .
i67> MMBTU per year
Pilot Fuel Use Rate:
Pilot Fuel Gas Heating Value:
73,2 scfh
2225 Btu/scf
? 5 MMscf/yr
1-25 MMBTU/yr
Section 04- Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Pollutant
Condensate Tank
Uncontrolled
Controlled
(lb/bbl)
(16/bbl)
(Condensate
Throughput)
(Condensate
Throughput)
0.0030
0.0002
0.0004
0.0320
0.0010
0.0002
0.0000
0.00.16
Control Device
Uncontrolled
(Ib/MMBtu)
(waste heat
combusted)
Uncontrolled
(lb/bbl)
(Condensate
Throughput)
Pollutant
0 3104
Pilot Light Emissions
Uncontrolled
(Ib/MMBtu)
Uncontrolled
(Ib/MMscf)
(Pilot Gas
Throughput)
(Pilot Gas Heat
Combusted)
0,0075
.0.0075 .
0.0406 32
.0.0680 ':%
o.OOS4
Emission Factor Source
Emission Factor Source
Emission Factor Source
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
0.0
0.0
0.0
0.0
0.0
0.0
0.5
0.0
..-,
1.2
0.0
0.0
71.0
. 0.P,
0 t
0.1
.-
0.1
_
.,..
7 5
1.s
.:-
7.1
- -
64.1
P._
02
0.2 .
D i
0._
50.,
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
' Actual Emissions
Uncontrolled Controlled
(Ibs/year) (16s/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
126.7 1 •.
25 3
i.3
126 7
76.0
152
., ..
76.0
5.r
i.0
3.1
5.1
0.3
2 of
KAPA\2014\14WE0196.CP3
Storage Tank(s) Emissions Inventory
Xylene
n -Hexane
224 TMP
10 1
810.6
25.3
2.0
0.1
8.1
9.3
101
Pi0.6
o.s
40.5
1.3
162.1
5.1
3 of 9 K:\PA\2014\14WE0196.CP3
Storaa4 ani si Emissions Inventory
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B .
Coerce ',seems uennit
Regulation 7, Part D,Section I.C,. D, E, F
Storage teak is subject r keasjusion 7, Part D 529
Regulation 7, Part D,Section I:G, C
Szorege Tanks nor s S ect to Regales.Ion 7, S.
Regulation 7, Part D,Section II.B, C.1, C.3
3.c stank is subject 7. Par: 7
Regulation 7, Part D,Section II.C.2
Sirs-ragenk is sub part p
Regulation 7, Part D,Section II.C.4.a.(i)
Storage Talk is our 5.., -.
Regulation 7, Part D,Section lLC.4.a.(ii)
Regulation 6, Part A, NSPS Subpart Kb
Storage Turk is c _
Regulation 6, Part A, NSPS Subpart 0000
Storage ank is not stU :5 CO
NSPS Subpart 0000a
t<:, _-.:'�0a
Regulation B, Part E, MACE Subpart HHx:-
See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
For condensate or crude oil tanks, does the company use the state default emissions factors t
estimate emissions? ;
If yes, 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
uncontrolled actual or requested 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 specific 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 efficiencygreater 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
Section 09 - SCC Coding and Emissions Factors (For Inventory Use Only),
AIRS Point if
902
Process if
01
SCC Code
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 6..,_ 0 lb/1,000 gallons Condensate throughput
PM2.5 _-__ 0 lb/1,000 gallons Condensate throughput
SOx C 7 0 lb/1,000 gallons. Condensate throughput
NOx 7.12- 0 lb/1,000 gallons Condensate throughput
VOC=..,,.z 6 lb/1,000 gallons Condensate throughput
CO D lb/1,000 gallons Condensate throughput
Benzene _._P 95 lb/1,000 gallons Condensate throughput
Toluene 5.07 95 lb/1,000 gallons Condensate throughput
Ethylbenzene x0,'09 95 lb/1,000 gallons Condensate throughput
Xylene 0,31 9!S lb/1,000 gallons Condensate throughput
n -Hexane 7.76 9S lb/1,000 gallons Condensate throughput
224 TMP 0.92 95 Ib/1,000: gallons Condensate throughput
4 of 9 KAPA\2014\14W E0196.CP3
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below ore determined based on requested emissions.
Colorado Re• ulation 3 Parts A and B-APEN and Permit Requirements
lib, is n-.na Mon -Attainment ttre
ATTAINMENT
1. Are uncontrolled actual emissions from any crkeia pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section ll.D.l.a)? ® Source Requires an APEN. Go to
2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance an grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 5TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3. Part B, Section ll.D.3)?
You brave. Indicnmd fl ax a -acute, die P3-n_-tau.menr Ar e
NON -ATTAINMENT
L Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section ll.D.l.al?
L Is the construction date (service date)prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and section 2for additional guidance an grandfather applicability)?
3 Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO embslons greater than 101PY(Regulation 3, Part&Section ll.D.2)7
Colorado Regulation, Part D,Section l.C-F&G
L Is the storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area (Regulation 7, Part D,Section lA.1)?
2. Is this storage tank located at ail and gas operations that collect, stare, or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processing plant (Regulation 7, Part 0, Section I.A.1)?
3 Is this storage tank located at a natural gas processing plant (Regulation 7, Part D, Section I.G)?
4. Does this storage tank contain condensate?
5. Does this storage tank exhibit "Flash. (e.g. storing non -stabilized liquids) emissions (Regulation 7, part D, Section l.G.2)?
L Are uncontrolled actual emissionsof this storage tank equal to or greater than 2 tons per year VOC (Regulation 7, Part D, section 1.0.3.a ill)?
'Storage tank is subimt m Pleaulo,ion --
Part D, Section I.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage
Part 0, Section I.C.2—Emission Estimation Procedures
Part D, Section 113 —Emissions Control Requirements
Part O, Section I.E— Monitoring
Part D, Section I.F— Recordkeeping and Reporting
gtoragc frank Is nut sub).A to Regulation 1: Sean. aca
Part D, Section I.G.2- Emissions Control Requirements
Part D, Section I.C.1.a and b —General Requiremenmfor Air Pollution Control Equipment —Prevention of Leakage
Colorado Regulation 7, Part D. Section II
L Isthisstorage tank located at a transmbsion/storage facility?
2. Is this storage tank' located at an oil and gas exploration and production operation, well production facility', natural gas compressor stations or natural gas processing plant° (Regulation 7, Part D, Section II.C)?
3 Does this storage tank have a fixed roof (Regulation 7, Part D,Section ll.A.2.0)?
4. Are uncontrolled actual emissions of this store eMnkequal to or RTeeter than 2 tons peryear VOC (Re ulation 7, Part D, Section ll.Gl.c?
fioragetmk is suited in Regular on-1.Pargra5 -
Part D, Section II.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Part D, Secd.n II.C.1- Emissions Control and Monitoring Provisions
Part D,Section II.C.3 - Recordkeeping Requirements
5. Does the storage tank contain only "stabilized"liquids (Regulation 7, Part D, Section ll.C.2.6)7
Yes
Go to next question
Source Requires a permit
Source Requires an APEN. Go to
Go to next question
Source Requires a permit
Continue - You have indicated th
Continue - You have indicated th
Storage Tank Is not subjectto RE
Continue- You have Indicated th
Go to the next question -You ha
Go to the next question
Source is subject to parts of Reg
Source is subject to all provision
Part D, Section II.C.2- Capture and Monitoring for Storage Tanks Fitted with Air Pollution Control Equipment
Is the controlled storage tanklocated at a wellproduction f 'Irtynatural gpessorstahon, or natural gas processng plant constructed on or after May 1, 2020 or located at a facility that was modified an or after Ma, 1, 2020, such
6_ that an addkional controlled storage vessel is constructedto receive an anticipated increase in throughput of hydrocarbon igmds or produced water(Regulation 7, Part D, Section ll.CM1a.()? tr.. Storage Tank is not subject to Re
Is the controlled storage tank l [ d at a wellp d ct f IRy natural gas p or station, or natural gas processing plant constructed on or after January 1, 2021 or located at a facility that was modified on or after January 1,
7 2021, such that anaddtonal controlled storage vessel is constructed to receive an anticipated increase lnthroughput of hydrocarbon liquids or produced water (Regulation 7, Part D, Section ll.C4a(,)T M1!c
40 CFR. Part 60. Suhnert Kb.5tandards of Performance for Volatile Organic Liquid Storage Vessels
L Is the lndividuakstorage vessel capacity greater than or equal to 75 cubic meters lm'1[-472 BBLs](40 CFRB0.110b(a))?
1. Does the storage vessel meetthe following exemption In 60.111b(d)(4)?
a. Does the vessel has a design capacity less than or equal to 1,589.874 m3(`10,000 BBL] used for petroleum' or condensate stored,processed, or treated prior to custodytransfer' as defined in 60.111b?
3 Was this storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1994 (40 CFR60.1106(a))?
4- Does the tank meet the definition of "storage vessel"' in 60.111b?
S. Does the storage vessel store a"volatile organic liquid(VOL)"'as defined in 60.111b?
G. Does the storage vessel meet any one of the following additional exemptions:
a a.Isthe storage vessel a pressure vessel designed to operate In excess of 204.9 kPa(-29.7 psi] and without emissions to the atmosphere (60.11ob(dll2))?;or
b. The design capacity h greater than or equalto 151 ms [-950 BBL] and stores a liquid with a maximum true vapor pressures less than 3.5 kPa (60.1106(b))7; or
c The design capacity is greater than or equal to 75 Ms grt172 BBL] but less than 151 ma (.950 BBL] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110b(b))7
T. Does the storage tank meet either one of thefollowing exemptions from control requirements:
a. The design capacity is greater than or equal to 151 ma [-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 greater than or equal to 75 Ms [-472 BBL] but less than 151 ms ['950 BEM and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 WM but lessthan 27.6liPa?
'Stir' • xon'r.'s-... eu
40 CFR. Part 60. Subpart 0000/0000a, Standards of Performance for Crude Oil and Natural Gas Production Transmission and Distribution
L Is this storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
2. Was this storage vessel constructed, reconsructed,or. modified (see definitions,. CFR, 60.2) between August 23, 2011 and September 18, 2015?
3 Was this storage vessel constructed, reconstrurted, or modified (see definitions 40 CFR, 60.2) after September 18, 20157
4'. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year?
5, Does this storage vessel meet the definition of"storage vessel"' per 60.5430/60.543067
6 Isthe store evessel subject to and controlled in accordance with re urements for storage vessels in 40CFR Part 60 Subpart Kb or. CFR Part 63 Sub art HH7
Go to the next question
Storage Tank is not subject NSPS
Xe52°;tt -
4401..?.''�n'r.9
weam
[Nate: If a storage vessel Is previously determined to be subject to NSPS 0000/0000a due to emissions above 6 tans per year VOC an the applicability determination date, It should remain subject[. NSPS 0000/0000a per
60.5365(e)(2)/W.53e5a(e)(2) even if potential VOC emissions drop below limns per year?
W CFR. Part 63. Suhnert MAR HR, Oil and Gas Production Facilities
L Is the storage tank located at an oil and natural gas production facility that meets either of the following cider.)
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 prior tothe point at which natural gas enters the natural gastmnsmission and sorage source category.. o delivered to a final end user' (63.760(a)(3))?
2 Is the tank located at a facility that a major3 for HAPs?
3 Does the tank meet the definition of"storage vessel"' in 63.761?
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 Subpart 0000?
Continue - You have indicated th
Go to the question 4.
Storage Tank is not subject NSPS
Storage Tank Is not subject NSPS
Iva 'Continue- You have indicated th
Subpart A, General provisions per 463.764 (a) Table 2
§63.]66 - Emissions Control Standards
463,773 Monitoring
§63.774-Recordkeeping
463.775 Reporting
RACE Review
PACT review Is required If Regulation 7 does not apply AND If the tank is In the non -attainment area. If the tank meets both criteria, then review RACT requirements.
Disclaimer
Storage Tank is not subject MAC
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 analysisit contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any 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 mill control. The use of non -mandatory language such as "recommend,"7nay,""should,"end "can," is intended to
describe APO() 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.
Section 01- Administrative Information
(Facility AIRS ID:
County
Plant
Point
Section 02 -Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Is this loadout controlled?
Requested Overall VOC & HAP Control Efficiency %:
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Hydrocarbon Loadout
Actual Volume Loaded =
'Requested Permit Limit Throug4 put=
Potential to Emit (PTE) Volume Loaded =
Barrels (bbl) per year
a -2.1% Barrels (bbl) per year
Requested Monthly Throughput= __a_ Barrels (bbl) per month
Secondary Emissions -Combustion Device(s)
F' 0A'T,v'Bamels(bbl)peryear
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?
MMBTU per year
MMBTU per year
MMBTU per year
Friona %au,
Emission Factor
Hydrocarbon Loadou
Pollutant
Control Device
Pollutant
Pilot Light E
fissions
Pollutant
Uncontrolled Controlled
(Ib/bbl)
Uncontrolled
(Ib/MMBtu)
(Ib/bbl)
Uncontrolled
(lb/bbl)
Uncontrolled
(IdJMMBtu)
Uncontrolled
(Ib/MMscf)
(Pilot Gas
Throughput)
(Waste Heat Combusted)
Emission Factor Source
Emission Factor Source
Emission Factor Source
PM10
PM2.5
SOx
NO
VOC
CO
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KAPA\2014\14W E0196.CP3
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) Dons/yeer)
Requested Monthly Limits
Controlled
(Ibs/month)
PM10
PM2.5
NOx
VOC
CO
...,
.,
:..,,
.._
_..,
....'
....
.,,.
l'.:.
.. v_
,..X:
, ..
...E
..;.
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
Ohs/year) -
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(los/year) (Ibs/year)
Benzene
Toluene
Ethylhenzene
Xylene
n -Hexane
224 TMP
....
_..
_..
- .
-
-
za
+->
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7 Part D Section II.C.5.
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
.,,.:ave ‘nd.cated abbae the sor.:.:e:s not wnt:ctied.the foil hwing q oes:.!' b ,t,ees .sit .eqa. . „
Section 08 - Technical Analysis Notes
Section 09 - SCC Coding and Emissions Factors ( For Inventory Use Only(
AIRS Point a
004
Process IS
01
SCC Code
Uncontrolled
Emissions
Pollutant Factor Control% Units
PM10 lb/1,000 gallons transferred
PM2.5 lb/1,000 gallons transferred
SOx .. lb/1,000 gallons transferred
NOx 16/1,000 gallons transferred
VOC- lb/1,000 gallons transferred
Co lb/1,000 gallons transferred
Benzene ,,.. ih/1,000 gallons transferred
Toluene lb/1,000 gallons transferred
Ethylhenzene - lb/1,000 gallons transferred
Xylene lb/1,000 gallons transferred
n -Hexane lb/1,000 gallons transferred
224 TMP lb/1,000 gallons transferred
8 of 9 KAPA\2014\14W E0196,CP3
Hydrocarbon LOadout Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions and throughput.
{'>,leredoie talon 3 Parts A and B.AP6N prtd Permit Requirements
ATTAINMENT
1. Are uncontrolled actual 1expor atom any criteria pollutants from tins individual source greater man 23, IRegulaa'on3. wrc A, Section u.4.1.a1?
z. Is the ioaaouuhmredat an out opepmmdonand g proless talnn site lo,000 gall ns(23pad) IRe n . 1.11?
lathe loadou loading bls pervert of 1230
condensate
oil per annual average hasls?
0. Is me loadout operation loading less man 6,0'x0 bbis peryearof contlematcevla splasdM1 011? an
5. Is Me loadout operation loading less than 35,300 bbis per year of condensate via submerged m1 procedure?
6. Are otalfacllry uncontrolled VOCemissions greater than 5 TPy, NOR greater than 10 TPY or CO emissions greater than 30 IVY (Regulation 3, Part B, Section 11.4.3)?
fill Mae a.,listed _ha.sour, !mg the .ca Atta.n_._nt..oa
.NOWATTAINMENT
1. Are rconbdfed emissiors from any criteria pollutants from Mix Individual source greater than STPy (Regulation 3, Part A, Section II.0.].al?
2, s...lout looted at an exploration and production site (e.g.. vrell pad)10egulatlon 3, Part B, Section II.D.I.Nty
Is Me loadout operation leading less than 10,000 gallons 123e BBL.) of crude d1 per day on an annual average bass?Is Meicodoutaperafan leading less than 6,750 bas per year of condensate via splash DI?
5. Is meloadout operation loading less than gg,30g Mk per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOeemissions from the greater than 2 TPY, NOR greater than 5 SPY of CO emasom greater than 1OTPY igeguiagam 3, Part B, Section ll.D.2)
i dPAeCPIdbn?Bart D sen@nWr=€
1. Is this condensate storage tank hydrocarbon liquids Iodout located eta well production facility, natural gas mnpressorstadm or natural gas processing plant?
? Does the facility have a throughput of hydrortrton liquids losclout to transport vehkles greater than or equal oso00 barrels?
IIn. u!da dtit OSercl»n I('5
on II.Gs.a.l7 -Compliance Schedule
Ceram II.C5a.(g)-operation without Venting
on II.CS.afiTl)-toadout Equipment Operation and Maintenance
Section llC5a.liv)- Loadout abservauare and Operator Training
Section ll.C.5.a.(v)-Records
Section Ibes.alail-Requirements for Air Pollution Control Equipment
This daimon, assists operators with determining appbcadlity of certain requirements Mahe Clean Air Act its Nnplamentirg regulabOns, and Air Quality Cunha Commission regulations. This document is nct a
ruleormutation, and the analysis ',contains may not apply to a particular situation based upon the individual facts and circumstances_ This document does not change or substitute b any law, regaled'., or
any other legally binding regdrement and is nc, legally enforceable. In the event Many pct behseenthe language Mt?is document and die language of the Clean Air Act, its implementing regulations,
and Air Quality Cohol Commission regulations, the language of the Meath or reguhnon will control. The LattM rte -mandatary language such asrecoarard,""may,""should,"end"cen,"is interfere to
describe APCO interpretations and recommendations. Mandatary termtobgy such as Int, and" required' he intended. describe controlling requirements under the terms of the Clean Air Act and Air
QralityContN Commission regulations, but thls document does not establish legally binding requirements in and anseM
Soto next Yec'iGom question.
the next question
•VOOVII Go tom. u.stion
Go next question
Go
The I d quires a permit
Dort next question.
source a subject to Regulation? Part 0 Section I.C.5.
Boma
CREEK
June 25, 2020
Stefanie Rucker
Colorado Department of Public Health and Environment
Air Pollution Control Division, APCD-SS-61
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
410 17th Street, Suite 1400
Denver, CO 80202
(720) 440-6100 phone
(720) 305-0802 fax
RE: Permit Modifications — CNDTK 8 TLO
State Antelope P-16 Production Facility (COGCC #432999, AIRS ID: 123/9BDD)
Bonanza Creek Energy Operating Company, LLC
Weld County, CO
Ms. Rucker,
✓O/ ri
1 20�0
Bonanza Creek Energy Operating Company, LLC (BCEOC) is pleased to submit the attached APENs and
supporting documentation for the condensate tank battery (CND -01, AIRS Point 002) and truck loadout (L-
01, AIRS Point 004) at the State Antelope P-16 Production Facility (COGCC #432999, AIRS ID:
123/9BDD).
State default emission factors and throughput from the 12 -month period beginning January 2019 were
used to calculate actual and requested emissions for the truck loadout while emission factors from permit
#14WE0196 Issuance 2 were used to calculate emissions for the condensate tank battery. BCEOC is not
requesting control for the truck loadout at this time. Controls will be installed by May 1, 2021 in order to
comply with Regulation 7, Part D Section II.C.5 if necessary.
In addition to the APENs, emissions calculations, and all other required documentation, a check covering
two (2) APEN filing fees totaling $382.26 is included herein.
If you need additional information regarding this modification application, please contact me at (303) 803-
1752 or via email at asoehner@bonanzacrk.com.
Sincerely,
Alisson Soehner
Environmental Engineer, Air Quality
Attachments: As stated
cc: File
CORPORATE OFFICE
4Th tF�Slreel. Suite 1400
Denver CO R0?03
Office /'?01440.6100
Form APCD-100
COLORADO
Department of Public
Health & Environment
Oil & Gas Industry
Construction Permit Application Completeness Checklist
Company Name:
Source Name:
Date:
Ver. November 29, 2012
Bonanza Creek Energy Operating Company, LLC (BCEOC)
State Antelope P-16 Production Facility (COGCC #432999)
June 2020
Are you requesting a facility wide permit for multiple emissions points?
Yes No
0 ❑
In order to have a complete application, the following attachments must be provided, unless stated
otherwise. If application is incomplete, it will be returned to sender and filing fees will not be refunded.
Attachment
Application Element
Applicant
APCD
A
APEN Filing Fees
Q
Q
B
Air Pollutant Emission Notice(s) (APENs) &
Application(s) for Construction Permit(s) — APCD Form Series 200
Q
C
Emissions Calculations and Supporting Documentation
Q
D
Company Contact Information - Form APCD-101
Q
■
E
Ambient Air Impact Analysis
0
❑
DI Check here if source emits only VOC (Attachment E not required)
F
Facility Emissions Inventory — Form APCD-102
Q
■
Check here if single emissions point source (Attachment F not required)
G
Process description, flow diagram and plot plan of emissions unit and/or
facility
UI Check here if single emissions point source (Attachment G not required)
Q
H
Operating & Maintenance (O&M) Plan — APCD Form Series 300
Q
■
I■ Check here if true minor emissions source or application is for a general
H
permit (Attachment not required)
I
Regulatory Analysis
D 1 Check here to request APCD to complete regulatory analysis
Q
IIIII
(Attachment I not required)
J
Colorado Oil and Gas Conservation Commission (COGCC) 805 Series Rule
Requirements— Form APCD-105
El
0
Check here if source is not subject to COGCC 805 Series requirements
J
(Attachment not required)
Send Complete Application to:
Colorado Department of Public Health & Environment
APCD-SS-BI
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Check box if facility is an existing Title V source: ❑ Send an additional application copy
Check box if refined modeling analysis included: n Send an additional application copy
Check box if application is for major NA NSR or PSD permit: n Send eight (8) total application copies
Page 1 of 1 FormAPCD-100-AppCompleteChecklist-Ver 1 1-29-2012.docx
Bonanza Creek Energy Operating Company, LLC. - State Antelope P-16 Production Facility (COGCC #432999)
Condensate Tank Site Specific Emission Factor Calculations
Emission Source: Condensate Tanks
Designed Throughput: 14 bbl/day
Designed Throughput: 5,066 bbl/yr
Requested Throughput: 25,331 bbl/yr
Enclosed Flare VOC Control Efficiency: 95%
Operating Days per Year: 365 daystyr
Total Emissions
Emission
Pollutant
Factors Iat
(lb/bbl)
Actual Emissions (tpy) (b)
Requested Emissions (tpy) (`I
Uncontrolled
Controlled
Uncontrolled
Controlled
VOC
0.59
1.49
0.07
7.47
0.37
Benzene
0.005
0.01
0.00
0.06
0.00
Toluene
0.003
0.01
0.00
r 0.04
0.00
Ethylbenzene
0.000
0.00
0.00
0.00
'
0.00
Xylenes
0.000
0.00
0.00
0.01
0.00
n -Hexane
0.0317
0.08
0.00
0.40
0.02
224-TMP
0.001
-
0.00
0.00
0.02
!
0.00
Notes:
(a) Emission Factors from Permit 14WE019612 issued on March 6. 2019
(b) Uncontrolled Emissions (toy) _ (Emission Factor, Itvbbl)' (Actual Throughput, bbl/yr) / (2,000 Ibtlon)
(c)Requested Emissions (tpy) _ (Actual Emissions, toy) -5
Bonanza Creek Energy Operating Company, LLC. - State Antelope P-16 Production Facility (COGCC #432999)
Enclosed Combustion Device (ECD) Emission Calculations for Condensate Tank Battery 1
Emission Source:
Condensate Tanks
-
- ---------------
Source Type:
--------
ECD
Heat Input Requested:
0.22 MMBtu/hr
Heat Input Actual:
0.17 MMBtu/hr
Gas Oil Ratio (GOR):
8.83 scf/bill
Tank Vent Gas Flowrate Requested:
25.5 scf/hr
Tank Vent Gas Flowrate Requested:
0.22 MMscf/yr
Tank Vent Gas Flowrate Actual:
5.1 scf/hr
Tank Vent Gas Flowrate Actual:
0.04 MMscf/yr
Pilot Gas Flowrate:
18.3 sd/hr
Pilot Gas Flowrate:
0.16 MMscf/yr
Endosed Combustors On Site:
4.00
Total Pilot Gas Flow Rate:
0.64 MMscf/yr
Total Flowrate to Combustor Including Pilot:
0.69 MMscflyr
Estimated HHV:
2,225 Btu/scf
Total VOC Control Efficiency:
95%
Sulfur Content of Fuel:
0.0020 gr/scf
Operating Hours per Year:
8.760 hr/yr
Pollutant
Emission Factors or
Uncontrolled Emissions (')
Actual Emissions
Requested Emissions
lb/hr jN' I`)
tpy I')
lb/hr (q' W
I
tpyld)
CO,
116.98 Ib/MMBtu
20.38
89.27
25.70
112.56
N20
0.00030 lb/MMBtu
0.00
0.00
0.00
- 0.01
NO
0.068 Ib/MMBtu
0.01
j
0.05
0.01
0.07
CO
0.310 Ib/MMBtu
0.05
_
0.24
0.07
1
0.30
SO2
0.00030 Ib/MMetu
0.0001
0.0002
0.0001
0.0003
PM,b
40.0 14 /1
0.0006
0.003
0.0012
0.0051
Pm25
4o.o N9 /1
0.0006
0.003
0.0012
0.0051
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 conservativeas this unit is smokeless in design).
SO, emissions based on AP42, which is based on 100% conversion of sulfur to SO, at 2000 grains/MMscf.
CO2 and N20 emission factors from 40 CFR Pan 98 Table C-1 and C-2 for Natural Gas.
(b) Hourly Emission Rate (lb/hr) except for PM,) _ (Emission Factor, lb/MMEttu) • (Heat Input. MMBtulhr)
(c) (scf CHIN) (10.6 scf E/scf CH,;) (0.0283 m%scf E) (40 p Pfvtgl E) (1000 Um') WO' pg) gb/463.59 g) i (hr/yr) =1b PMni hr
(d) Annual Emission Rate (tpy) _ (Hourly Emission Rate. Iti/hr)Ou/yr) 7 (2.000 Ibrton)
Table C-5
(a)
(b)
Bonanza Creek Energy Operating Company, LLC. - State Antelope P-18 Production Facility (COGCC #432999)
Requested VOC Emissions from Truck Loading (AP -42 Chapter 5.2 (1/95))
Site
Product
Loading Mode
Sales
Saturation
Factor
(S)1')
True Vapor
Pressure (P)
[psla]
Molecular
Weight (M)
[Ib/Ib-mol]
Bulk Temp.
(T) [F]
Uncontrolled
Loading Loss
(LL) (h)
[ibibbl]
Requested
Uncontrolled
VOC
Emissions
Control
Efficiency
(%)
Requested
Controlled VOC
Emissions
State Antelope P-16
Condensate
Submerged, Dedicated
Normal Service
25,331 bbl/year
0.6
N/A
N/A
64
0.236
3.0 tpy
Uncontrolled
3.0 tpy
Source: AP -42 Table 5.2-1 (1/95)
Equation 1 for loading losses: (12.46) • (SPM / T)' W= L,
Where:
Li = loading losses, Ibs/1000 gal of liquid loaded
S = saturation factor
P = true vapor pressure of equid loaded (own) based on regression analysis for crude oil (AP 42 Chapter 7.1 page 56) and a reid vapor pressure of 9.6 psis
M = Molecular wt of vapors lb/lb-mot estimated using AP 42, Table 7.1-2 and a raid vapor pressure of 9.6.
T = temperature of bulk liquids loaded °R (°F = 460) from EPA TANKS Meterological Database for Denver. CO
AP -42 Chapter 5.2, Table 5.2-1 (1/95)
Tank trucks and rail tank cars Submerged loading of a clean cargo tank
0.5
Submerged loading: dedicated normal service
0,6
Submerged loading: dedicated vapor balance service
1.0
Splash loading of a clean cargo tank
1.45
Splash loadingdedicated normal service
1.45
Splash loading: dedicated vapor balance service
1
Marine vesselsa Submerged loading. ships
0.2
Submerged loading, barges
0.5
Wt. % of
HAP THC la)
Loading Loss
lb/bbl
Uncontrolled HAP Emissions (e)
Controlled HAP Emissions WI
Benzene 0.0000%
t
0.00041
10.39 lb/yr
0.01 tpy
10.39 Ib/yr
0.01 tpy
. Toluene 0.0000%
0.0000
0.00 Iblyr
0.00 tpy
0.00 Ib/yr
0.00 tpy
Ethylbenzene 0.0000%
0.0000
0.00 Ib/yr
0.00 tpy
0.00 lb/yr
0.00 tpy
Xylenes j 0.0000%
0.0000
0.00 lb/yr
0.00 tpy
0.00 ib/yr
0.00 tpy
n -Hexane j 0.0000%
0.0036
91.19lb/yr
0.05 tpy
91.19 ib/yr
0.05 tpy
2,2,4-Trimethyipentane 0.0000%
0.0000
D.00 Ib/yr
0.00 tpy
0.00 Ib/yr
0.00 tpy
Total
101.58 Ib/yr
0.05 tpy
101.58 lb/yr
0.05 tpy
(c) Based on Condensate Composition
(d) HAP Emissions, tpy = (VOC Emissions, toy) - (HAP WI. % of THC)
Table C-5
Bonanza Creek Energy Operating Company, LLC. - State Antelope P-18 Production Facility (COGCC 0432999)
Actual VOC Emissions from Truck Loading (AP -42 Chapter 5.2 (1/95)1
Site
Product
Loading Mode
Sales
Saturation
Factor
(S) (°)
True Vapor
Pressure (P)
[psia)
Molecular
Weight (M)
(lblib-moi]
Bulk Temp.
(T) (F]
Uncontrolled
Loading Loss
(LL) lb)
(Ib/bbl)
Actual
Uncontrolled
VOC
Emissions
Control
Efficiency
rAl
Actual Controlled
VOC Emissions
State Antelope P-16
Condensate
Submerged, Dedicated
Normal Service
5,066 bbl/year
0.6
N/A
N/A
64
0.236
0.6 tpy
Uncontrolled
0.6 tpy
(a) Source: AP -42 Table 5.2-1 (1/95)
(b) Equation 1 for loading losses (12.46) • (SPM / T)' W = Li
Where.
L, = loading losses. Ibs/1000 gal of liquid loaded
S = saturation factor
P = hue vapor pressure of liquid loaded (psis) based on regression analysis for crude oil (AP 42 Chapter 7.1 page 56) and a reid vapor pressure of 9.6 psia
M = Molecular vet of vapors Ib/lb-mol estimated using AP 42, Table 7.1-2 and a reid vapor pressure of 9.6.
T • temperature of bulk liquids loaded "R ("F = 460) from EPA TANKS Materological Database for Denver, CO
AP42 Chapter 5.2, Table 5.2-1 (1195)
Tank trucks and rail tank cars Submerged loading of a clean cargo tank
0.5
Submerged loading: dedicated normal service
0,6
Submerged loading. dedicated vapor balance service
1.0
Splash loading of a clean cargo tank
1.45
Splash loading: dedicated normal service
1.45
Splash loading- dedicated vapor balance service
1
Marine vesselsa Submerged loading: ships
0.2
Submerged loading: barges
0.5
Wt. %of
HAP THC (`)
Loading Loss
Iblbbl
Uncontrolled HAP Emissions (d)
Controlled HAP Emissions (d)
Benzene ! 0.0000%
0.00041
2.08 Ib/yr 0.00 tpy
2.08 Ib/yr
0.00 tpy
Toluene I 0.0000%
0.0000
0.00 Ib/yr 0.00 tpy
0.00 Ib/yr
0.00 tpy
Ethylbenzene
0.0000%
0.0000
0.00 ib/yr 0.00 tpy
0A0 lb/yr
0.00 tpy
Xylenes
0.0000%
0.0000
0.00 Ib/yr 0.00 tpy
0.00 Ib/yr
0.00 tpy
n -Hexane
0.0000%
0.0036
18.24 Iblyr 0.01 tpy
18.24 Ib/yr
0.01 tpy
2,2,4-Trimethyipentane
0.0000%
0.0000
0.00 lb/yr 0.00 tpy
0.00 Ib/yr
0.00 tpy
Total
20.32 lb/yr I 0.01 tpy
20.32 Ib/yr
0.01 tpy
(c) Based on Condensate Composition
(d) HAP Emissions, tpy = (VOC Emissions, tpy) ' (HAP Wt. % of THC)
Form APCD-101
COLORADO
Department of Public
Health & Environment
Company Contact Information Form
Ver. September 10, 2008
Company Name: Bonanza Creek Energy Operating Company, LLC (BCEOC)
Source Name: State Antelope P-16 Production Facility (COGCC #432999)
Permit
Contacts:
Alisson Soehner
Address:
410 17th Street, Suite 1400
Street
Denver
CO
80202
City
State
Zip
Phone Number:
(303) 803-1752
Fax Number:
(720) 305-0804
E-mail:
asoehner@bonanzacrk.com
Billing Contact:
(Permit Fees,Z
Alisson Soehner
Address:
410 17th Street, Suite 1400
Street
Denver
CO
80202
City
State
Zip
Phone Number:
(303) 803-1752
Fax Number:
(720) 305-0804
E-mail:
asoehner@bonanzacrk.com
Compliance
Contact':
Matt Cannizzaro
Address:
410 17th Street, Suite 1400
Street
Denver
CO
80202
City
State
Zip
Phone Number:
(303) 803-1752
Fax Number:
(720) 305-0804
E-mail:
mcannizzaro@bonanzacrk.com
Billing Contact:
(Annual FeesZ
Alisson Soehner
Address:
410 17th Street, Suite 1400
Street
Denver
CO
80202
City
State
Zip
Phone Number:
(303) 803-1752
Fax Number:
(720) 305-0804
E-mail:
asoehner@bonanzacrk.com
Check how would you like to receive your permit fee invoice?
Mail: Ej
E-mail: Q
Fax: n
Footnotes:
The permit contact should be the point of contact for technical information contained in the permit application.
This may be a company representative or a consultant.
3. The compliance contact should be the point of contact for discussing inspection and compliance at the permitted
facility.
3 The billing contact (Permit fees) should be the point of contact that should receive the invoice for fees
associated with processing the permit application & issuing the permit. (Reg. 3, Part A. Section VI.B)
a The billing contact (Annual fees) should be the point of contact that should receive the invoices issued on an
annual basis for fees associated with actual emissions reported on APENs for the facility. (Reg. 3, Part A,
Section VI.C)
Page 1 of 1 AP_Form-APCD-1 0 1 -Company -Contact -Information (2)doc
Attachment E -Ambient Air Impact Analysis
Note: This facility will not exceed the modeling thresholds noted
within Table 1 of Colorado Modeling Guideline for Air Quality
Permits. Therefore, an ambient air quality impact analysis is not
required.
Form APCD-102
Company Name: Bonanr Creek Energy Operating Company, LLC.
Source Name: Stale Antelope P-IG Production Facility {COGCC #412'4)9)
Source AIRS ID: 123.9BDD
Colorado Department of Public Health and Environment
Air Pollution Control Division
Facility Wide Emissions Inventory Form
Vet. April. 2015
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1 This form should be conipkted to include both existing sources and all proposed nee
2. If the emissions source is nen dim, enter "proposed" under the Permit No. and AIRS
1 HAP abbresIliions include
8Z - Bunten.
TnI = Toluene
E8 = Elhn lbemrene
xyl = x> lone
HERO - Formaldehyde
4 APFN Exempt/Insignificant Sources should be included nhen narmored
or modifications to exising emissions sources
IDdata columns
224-TMP - 2.2 44Trimethylpentane
Acelal = Acetaldehyde
Aery = Acrolein
mHex = n -Hexane
Meth - Methanol
SP
Boma
CREEK
Process Description
State Antelope P-16 Oil & Gas Production Facility
State Antelope P-16 Production Facility (COGCC #432999) is an existing oil and gas production facility
located within the eight -hour (8 -hr) Ozone Control Area of Weld County. The facility produces both oil
and natural gas from two wells, State Antelope 41-44-16HNB and State Antelope 31-34-16HNB. The
facility consists of the following sources of emissions:
• Six (6) Condensate Oil Storage Tanks (500 bbl capacity each);
• Three (3) Produced Water Storage Tanks (2 @ 60 bbl capacity and 1 @ 400 bbl capacity);
• Four (4) Leed Model L30-0010 Enclosed Flares;
• Truck Loading Operation;
• Two (2) High/Low Pressure Separators;
• Two (2) Arrow C-101 Pump Jack Engines;
• Fugitive Equipment Leaks; and
• Two (2) Heaters (0.50 MMBtu/hr capacity).
Gas and oil produced from State Antelope 31-34-16HNB and State Antelope 41-44-16HNB are
processed through separators where liquids are separated from the natural gas at high pressure. The
overhead gas from the high pressure side of the separators is directed to pipeline. The liquids from the
high pressure side of the separators are sent to the low pressure side where oil and water are separated
and sent to onsite storage tanks before being trucked from the facility. The overhead gas from the low
pressure side of the separators is sent to the four enclosed flares for control. Flashing, working and
breathing loss vapors from the oil tanks and the 400 bbl water tank are routed to the enclosed flares. The
enclosed flares have a vendor guaranteed destruction efficiency of 95% or higher.
Finally, the heated separators, produced water tanks, and fugitive equipment leaks are all APEN exempt
emission sources emitting less than 2 tons per year of any single pollutant and/or 1 ton per year of VOC
(the facility is located within the nonattainment 8 -hour Ozone Control Area).
High/Low
Pressure
Separators
-1
Horizontal Wells
Pi oduuad lslaie�
State Antelope P-16 Production Facility
NE % NW % Sec. 16, T5N, R62W
Weld County, Colorado
6 400 bin
_r n anxata
Tank.,
Water Trucked Out
"ac—a�b
Oil Truck l oadout
S4
Bonanza
CREEK
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Form APCD-304
APCD Internal Use Only
Received Date
Approved? ❑ Approval Date
Operating and Maintenance Plan Template for
Condensate Storage Tanks
Ver. January 27, 2020
The Air Pollution Control Division developed this Operating and Maintenance Plan (OEtM Plan) for condensate
storage tanks that use emissions controls, permitted at synthetic minor and major oil and gas facilities in the State
of Colorado. One O8M Plan may be used for multiple tanks at one facility if each are controlled and monitored in
the same manner.
An O8M Plan shall be submitted with the permit application when required. The facility operator must comply
with the requirements of the O&M Plan upon commencement of operation. An existing approved OEtM Plan may
be modified without a permit modification or permit reissuance, but the operator must adhere to the requirements
of the existing approved OEtM Plan until an approval letter is issued for the new OEtM Plan.
The operator is required to use the division -developed O£tM Plan template forms in order to meet minimum
expectations within a standard, organized format. Do not modify the structure and/or content of this template.
If the facility or emissions unit is subject to other state or federal regulations with duplicative requirements, the
operator must follow the most stringent regulatory requirement.
Please note that O&M requirements are different for facilities in the Denver Metro and North Front Range 8 -hour
ozone nonattainment area.
For sources that are subject to the Title V Operating Permits program: In accordance with Colorado
Regulation No. 3, Part C, Section V.C.5., some or all of the monitoring specified in this O&M plan will be
incorporated as specific conditions in the source's Title V Operating Permit (if applicable). Additional monitoring
not listed in this O8M Plan may be included in the source's Operating Permit in order to satisfy the periodic
monitoring requirements of Regulation No. 3, Part C, Section V.C.5.b.
Submittal Date: June 2020
Section 1 - Source Identification
For new permits, some of this information (i.e., Facility AIRS ID, Permit Number, and AIRS Point ID) may not be known at the
time of application. Please only fill in the fields that are known and leave the others blank.
Company Name:
Bonanza Creek Energy
Operating Company, LLC
(BCEOC)
Facility
Location:
NENW, 5N, 16, 62W
40.40534,-104.32511
Facility Name: State Antelope P-16 Production Facility AIRS ID (for existing facilities) 123 - 96DD
Facility (COGCC #432999)
Is this facility located in the Denver
Metro and North Front Range 8 -hour
ozone nonattainment area?
® Yes
❑ No
Emission Units Covered by this ORM form
Facility Equipment ID
Permit Number
CND -01
14WE0196
AIRS Point ID
002
Page 1 of 4
GDPHE
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Section 2 - Maintenance Schedules
Check one of the following:
Facility shall follow manufacturer recommendations for the operation and maintenance of the emissions
unit and control devices. These schedules and practices, as well as all maintenance records showing
compliance with these recommendations, shall be made available to the division upon request.
Facility shall follow individually developed maintenance practices and schedules for the operation and
maintenance of emissions unit and control devices. These schedules and practices, as well as all
maintenance records showing adherence to these practices, shall be made available to the division upon
request and shall be consistent with good air pollution control practices for minimizing emissions as
defined in the New Source Performance Standard (NSPS) general conditions.
Section 3 - Recordkeeping Requirements
The following box must be checked for the 0&M Plan to be considered complete:
Synthetic minor and major sources are required to maintain maintenance and monitoring records for
the requirements of this O&M Plan for a period of five (5) years. If applicable state requirements or
any Federal NSPS, NESHAP, or MACT require a longer record retention period, the operator must comply
with the longest record retention requirement.
El
Section 4 - Monitoring Requirements
Check one of the following two boxes:
Check this box to confirm that the storage tank(s) are subject to the requirements of Regulation No.
7, Sections XVII.C.2. and C.3 (Storage Tank Emission Management System "STEM"). By checking this
box, the operator confirms adherence to the operating, maintenance, and recordkeeping requirements
of STEM as developed and implemented by the operator, as required by Regulation No. 7, Sections
XVII.C.2. and C.3.
►ZI
Check this box if the storage tank(s) are not subject to the requirements of Regulation No. 7, Sections
XVII.C.2. and C.3. ("STEM"). Leakage to the atmosphere shall be minimized as follows:
• Thief hatch seals shall be inspected monthly for integrity and replaced as necessary;
• Thief hatch covers shall be properly weighted and seated to ensure flashing, working, and breathing
losses (as applicable) are routed to the control device under normal operating conditions;
• Pressure relief valves (PRV) shall be inspected monthly for proper operation and repaired or
replaced as necessary;
• PRVs shall be set to release at a pressure that will ensure flashing, working, and breathing losses
(as applicable) are routed to the control device under normal operating conditions; and
• Inspections shall be documented with an indication of status, a description of any problems found,
and their resolution (e.g., adjustments made to thief hatch weight cover weight or PRV setpoint,
including the modified settings).
•
Page 2 of 4
CDPHE
COLORADO
Air Pollution Control Division
Department of Public Health Et Environment
Table 1 below details the monitoring parameters and frequency for control equipment depending on the type of
control equipment and the requested permitted emissions at the facility. Indicate the storage tank emissions
control by checking the appropriate boxes. In addition, check the appropriate box for "Monitoring Frequency"
based on the facility attainment area status and facility -wide permitted VOC emissions.
Table 1 I
Emissions Control
or
Recycling Method
Parameter
Monitoring Frequency
Ozone Nonattainment Area
Ozone Attainment Areas
❑ Permitted
Facility
Emissions
a 40 tpy VOC
Permitted
Facility
Emissions
a 80 tpy VOC
Permitted
Facility
Emissions
< 80 tpy VOC
►1 Permitted
Facility
Emissions
< 40 tpy VOC
Enclosed Flare
or Elevated
Open Flare a
®
Pilot Light / Auto -
igniter Monitoring
and
Visible Emissions
Observation
Daily b. c
Weekly b' c
Daily b, c
Weekly b. c
Vapor Recovery
Unit or
Recycled or
Closed Loop
System d
❑
Monitoring requirements, including parameters and frequency, to be determined by the
operator and listed below in footnote d.
Other
❑
Monitoring requirements, including specific parameters and frequency, to be described
in Section 5 below, and approved by the division.
a Elevated Open Flare
If the storage tank is subject to Regulation No. 7, Section XII or Section XVII, the use of an open flare must be
approved by the division as an alternate emission control device prior to operation in accordance with
Regulation No. 7 Section XVI1.B.2.e.; see PS Memo 15-03. Open flares permitted prior to May 1, 2014 are
approved for operation. All new open flares permitted on or after May 1, 2014 are required to obtain division
approval prior to operation.
b Pilot Light Monitoring Options
If the tanks are controlled by combustion device, then the operator must indicate in Table 2 the primary method
by which the presence of a pilot light will be monitored. One primary method for Pilot Light Monitoring must
be checked and, optionally, secondary methods may be checked.
Table 2: Pilot Light Monitoring
Primary
Secondary
Monitoring Method
/1
n
Visual Inspection
❑
❑
Optical Sensor
❑
_
Auto -Igniter Signal
❑
❑
Thermocouple
Page 3 of 4
CDPHE
COLORADO
Air Pollution Control Division
Department of Public Health Et Environment
Visible Emissions Observation and Method 22 Options
At the frequency specified in Table 1, the operator is required to conduct an inspection of the subject combustion
device for the presence or absence of smoke (e.g., visible emissions). If smoke is observed during the visible
emissions inspection, the operator has the option to either (1) immediately shut-in the emissions unit to
investigate the cause of the smoke, conduct any necessary repairs, and maintain records of the specific repairs
completed; or (2) conduct a formal Method 22 observation to determine whether visible emissions (as defined
per Regulation No. 7, Section XVII.A.17. ) are present.
If a Method 22 is conducted, the record of the observations shall be maintained as required in Section 3 of this
0&M Plan (Reference: Regulation No. 7, Section XVII.C.3.d). If visible emissions are observed by Method 22, the
operator shall immediately conduct any necessary repairs and maintain records of the specific repairs completed;
if repair cannot be immediately completed, the operator shall shut-in the emissions unit, conduct any necessary
repairs, and maintain records of the specific repairs completed.
If the emissions unit is subject to Regulation No. 7, Section XII.E, operators must document the required
inspections for the presence or absence of smoke. The division has historically approved a "check box" to satisfy
the documentation procedures referenced in Section XII. The division will continue to accept the "check box"
recordkeeping format in instances where no visible emissions are observed in order to demonstrate compliance
with Regulation No. 7 Section XII.E.4.a.
d Vapor Recovery Unit (VRU) or Recycled or Closed Loop System
In the space provided below, please provide a description of the emission control or recycling system, including
an explanation of parameters monitored, monitoring frequency, and how the system design ensures that
emissions are being routed to the appropriate system at all times, or during all permitted runtime. Also, provide
a description of how downtime is tracked and recorded.
N/A
Section 5 - Additional Notes and 0&M Activities
Please use this section to describe any additional notes or operation and maintenance activities, or if additional
space is needed from a previous section. Attach additional pages if necessary.
N/A
Page 4 of 4
ATTACHMENT I
Regulatory Applicability Information
This document provides regulatory applicability information to supplement the construction
permit application for Bonanza Creek Energy Operating Company, LLC's State Antelope P-16
Production Facility. An analysis of the applicability of state and federal air quality permitting
requirements and air pollution control regulations for the emissions sources is provided,
along with an appropriate explanation and rationale regarding the applicability or non -
applicability of specific regulations for the emissions sources.
Regulation 3: Permitting and ADEN Requirements
Regulation 3, Part A, Section II: The produced water tanks, heated separators, and fugitive
equipment leak emissions are not subject to APEN reporting. Uncontrolled actual emissions
of all criteria pollutants (except volatile organic compounds [VOC] and nitrogen oxides [NOx])
are less than 2 ton per year (tpy), and NOx and VOC emissions are less than 1 tpy within the
nonattainment 8 -hour Ozone Control Area [Regulation 3, Part A.II.B.3.a and Part A.II.D.1.a].
Regulation 3, Part B, Section II: The The produced water tanks, heated separators, and fugitive
equipment leak emissions are not subject to permitting because they are not subject to APEN
reporting [Regulation 3, Part B.II.D.1.a].
The two (2) Arrow C-101 engines are not subject to permitting because they have a
manufacturer's site -rating of less than fifty horsepower. [Regulation 3, Part B.II.D.1.c.(iiI)].
Regulation 3, Part B, Section III: Sources completing a permit to construct in designated
nonattainment areas with projected controlled annual emissions of any pollutant for which an
ambient air quality standard has been designated where such emissions will be greater than 25
tpy are subject to public comment and hearing requirements. The facility is subject to these
regulations because VOC emissions are greater than 25 tpy [Regulation 3, Part
Regulation 3 requires that new minor sources in designated nonattainment areas shall apply
Reasonably Available Control Technology (RACT) for the pollutants for which the area is
nonattainment or attainment/maintenance. The facility is a synthetic minor source within a
nonattainment area and is required to apply RACT to facility sources of NO. and VOCs. The
facility has met these requirements by following applicable requirement of Regulation 7 for
sources of NO. and VOCs on site.
Regulation 3, Part C: This facility will continue to operate as a synthetic minor source with
respect to the Title V Operating Permit Program. The facility will not be required to submit a
Title V Permit application within 12 months of startup.
Regulation 3, Part D: This facility is not a listed source in Regulation 3, Part D, Section II.A.25
and therefore would trigger Prevention of Significant Deterioration (PSD) requirements if
emissions exceed 250 tpy of any criteria pollutant. The facility is located in the nonattainment
8 -hour Ozone Control Area where a major source for non -attainment new source review (NA-
NSR) has the potential to emit more than 50 tpy for VOCs or NO.. This facility as proposed will
be a synthetic minor stationary source with respect to PSD and NA-NSR; therefore, it is not
subject to this regulation.
Regulation 6, Part B Non -Federal NSPS for Specific Facilities and Sources
Regulation 6, Part B Section I.C: Section II.C applies the most stringent federal new source
performance standards for internal combustion engines greater than 500 hp relocated to the state.
1
If the engine was relocated to the state more than 5 years after it was manufactured the operator
must consider relocation date for applicability to NSPS Subpart JJJJ and Supbart IIII. The engines
are rated at less than 500 hp and are subject to this rule.
Regulation 7, Part D Section I Oil and Gas Ozone Control Area Regulations
Regulation 7, Part D Section I.C: Section II.C applies to all condensate collection, storage and
handling facilities located in the 8 -hour Ozone Control Area. All new or modified storage
tanks after February 1, 2009 must control VOC by at least 95% during the first 90 days of
production. Any combustion device installed after January 1, 2017 must be
equipped with an auto -igniter. The tanks are subject to this section and were controlled
during the first 90 days of production. The combustion devices on site were installed prior to
January 1, 2017 and are equipped with auto -ignitors.
Regulation 7, Part D Section I.D.1, I.D.2, I.F.1 and I.F.1: These sections apply to all condensate
collection, storage and handling facilities located in the 8 -hour Ozone Control Area with
uncontrolled actual VOC emissions greater than 2 tpy. Operators with more than 30 tpy of
system wide uncontrolled emissions must reduce VOC emissions system -wide by at least 70% on
a calendar week basis from October through April and at least 90% from May through September
until April 30, 2020. Weekly system -wide controls must be reported to the Division. The
condensate tanks at this facility are not subject to these sections.
Regulation 7, Part D Section I.D.3 and I.F.2 and I.F.3: These sections apply to all condensate
collection, storage and handling facilities with uncontrolled actual VOC emissions greater than
2 tpy in the 8 -hour Ozone Control Area. Storage Tanks constructed on or after March 1, 2020
must control VOC emissions by at least 95% upon commencement of operations. Storage Tanks
constructed prior to March 1, 2020 must control VOC emissions by at least 95% by May 1, 2020.
Storage tanks must install controls within 60 days of exceeding 2 tpy uncontrolled actual VOC
emissions. The produced water and oil storage vessels are all manifolded together via a liquid
line and therefore are considered one "storage tank" for applicability purposes. The total
emissions from the storage tank are less than 2 tpy uncontrolled actual VOC emissions and are
not subject to these sections.
Regulation 7, Part D Section I.E: Section I.E applies to all existing storage tanks at oil and gas
production facilities required to be controlled under Regulation 7, Part D Section I.
Audio, visual, olfactory (AVO) inspections are required not more than every seven (7) days but
at least every thirty one (31) days until April 30, 2020. Starting May 1, 2020 weekly AVO
inspections are required. The storage tanks at this facility are not required to install control
equipment per Section I.D are thus not subject to this section.
Regulation 7, Part D Section I.L: Section I.L applies to well production facilities with
uncontrolled actual VOC emissions greater than 1 tpy (highest emitting tank or facility wide
emissions) and all natural gas compressor stations located in the 8 -hour Ozone Control area.
Compressor stations must conduct leak inspections quarterly starting within 90 days of startup.
Well production facilities must conduct leak inspections annually or semi-annually (depending
on emissions) starting within 30 days of commencing operations. This facility is considered a well
production facility with storage tanks. Based on the uncontrolled actual VOC emissions, this
facility is required to perform leak inspections on an annual basis.
Regulation 7, Part D Section II Oil and Gas State -Wide Regulations
Regulation 7, Part D Section II.C.1.: This section applies to all condensate collection, storage and
handling facilities with uncontrolled actual VOC emissions greater than 2 tpy statewide. Storage
2
Tanks constructed on or after March 1, 2020 must control VOC emissions by at least 95% upon
commencement of operations. Storage Tanks constructed prior to March 1, 2020 must control
VOC emissions by at least 95% by May 1, 2021. The produced water and oil storage vessels are all
manifolded together via a liquid line and therefore are considered one "storage tank" for
applicability purposes. The total emissions from the storage tank are less than 2 tpy uncontrolled
actual VOC emissions and are not subject to this section.
Regulation 7, Part D Section II.C.2 and II.C.3.: Section II.C.2 and II.C.3 applies to all storage
tanks at oil and gas production facilities required to be controlled under Regulation 7,
Part D Section I.D or II.C.1. A STEM plan must be developed and followed. Inspections
of the storage tank must occur Monthly, quarterly or semi-annually (depending on emissions).
The storage tanks are not subject to control requirements and is therefore not subject to this
section.
Regulation 7, Part D Section II.C.4.: Section II.C.4 applies to all storage tanks at oil and gas
production facilities, compressor stations and gas processing plants constructed or modified on
or after May 1, 2020. Storage tanks constructed or modified on or after May 1, 2020 must
install equipment to determine quantity of liquid stored. Storage tanks constructed
or modified on or after January 1, 2021 must install equipment to determine quantity
and quality of liquid stored. Signage must be posted and annual training is required. This
regulation does not apply to the storage tanks onsite because they were constructed prior to May
1, 2020 and have not been modified.
Regulation 7, Part D Section II.C.5.: Section II.C.4 applies to oil and gas production facilities,
compressor stations and gas processing plants that loadout 5,000 barrels per year or more of
hydrocarbon liquids. Facilities are required to use submerged fill and vapor return or control
equipment. Facilities constructed on or after May 1, 2020 must be in compliance upon startup.
Facilities constructed before May 1, 2020 must be in compliance by May 1, 2021. The facility is
subject to this section because it loads out more than 5,000 barrels of hydrocarbon liquid per year
and must be in compliance by May 1, 2021.
Regulation 7, Part D Section II.E.4: Section II.E.4 applies to well production facilities with
uncontrolled actual VOC emissions greater than 1 tpy (highest emitting tank or facility wide
emissions) and all natural gas compressor stations. This facility is considered a well production
facility with storage tanks that is not within 1,000 feet of an occupied area. Based on the
uncontrolled actual VOC emissions from the highest emitting tank, this facility is required to
perform AIMM inspections one time and AVO inspections monthly.
Regulation 7, Part D Section II.F: Section II.F applies to gas coming off a separator produced
during "normal" operations from newly construction, hydraulically fractured, or recompleted
wells after August 1, 2014. This facility is not subject to the gathering and control requirements
of Part D II.F because the wells onsite were constructed prior to August 1, 2014.
Regulation 7, Part D Section II.G: Section II.G applies to downhole well maintenance, well
liquids unloading events, and well plugging events. This facility is subject to the best
management practices, record keeping and report requirements of this rule for any
downhole well maintenance, well liquids unloading events, and well plugging events that occur
on site.
Regulation 7, Part D Section III: Section III applies to pneumatic controllers that are placed
in service on or after February 1, 2009 in nonattainment areas, and pneumatic controllers
statewide that are placed in service on or after May 1, 2014. The facility is located inside the non -
attainment area and has complied with this regulation by installing only pneumatic controllers
that emit VOCs in an amount less than or equal to a low -bleed pneumatic controller. This facility
3
will follow the inspection, enhanced response, record keeping and reporting requirements.
Regulation 7, Part D Section V: Section V requires oil and natural gas operations and
equipment at or upstream of a natural gas processing plant submit an annual actual emissions
report. The facility is located upstream of a natural gas processing plant and will follow the
reporting requirements of this section.
40 CFR 60, New Source Performance Standards
40 CFR 60 Subpart Kb - Standards of Performance for Volatile Organic Liquid Storage
Vessels (Including Petroleum Liquid Storage Vessels): Subpart Kb applies to storage vessels
which commence construction, modification or reconstruction after July 23, 1984. The storage
tanks located at the facility are exempt from the requirements of this subpart under
§60.110b(d)(4), as they are used for condensate storage prior to custody transfer and have a
capacity less than 1,589,874 m3.
40 CFR 60 Subpart OOOO - Standards of Performance for Crude Oil and Natural gas
Production, Transmission and Distribution for which Construction, Modification or
Reconstruction Commenced after August 23, 2011, and on or before September 18, 2015:
Subpart OOOO applies to affected facilities that commenced construction, reconstruction, or
modification after August 23, 2011 and on or before September 18, 2015. Affected facilities
include: gas well affected facilities; centrifugal compressors with wet seal degassing systems;
reciprocating compressors; continuous -bleed natural gas actuated pneumatic controllers;
storage vessels containing crude oil, condensate, produced water or a mixture thereof;
equipment leaks of VOC at natural gas processing plants; and sweetening units at natural gas
processing plants constructed, modified or reconstructed after August 23, 2011 and on or before
September 18, 2015. This facility is a well site and is neither a compressor station nor a natural
gas processing plant.
Storage Vessel Affected Facility: Each storage vessel constructed after August 23, 2011 and
before September 18, 2015, that emits VOC emissions at or greater than 6 tons per year
(as determined by the maximum average daily throughput) is subject to the emissions
control (95% DRE), recordkeeping and reporting requirements of this subpart. Legally
and practically enforceable limits may be accounted for in determining VOC emission
from storage vessels for applicability to this subpart. The storage tanks °mite were
constructed in January 2013, however each storage vessel emits less than 6 tons per
year after accounting for legally and practically enforceable limits, and as such the
storage vessels are not an affected facility under this subpart.
Pneumatic Controller Affected Facility: All continuous bleed pneumatic controllers must be
low or no bleed (56 scf/hr natural gas bleed rate). High bleed pneumatic controllers, if
they must be used, are subject to the tagging and reporting requirements of this subpart.
All pneumatic controllers at the site are either intermittent, low (56 scf/hr natural gas
bleed rate) or no bleed and as such not applicable to the tagging and reporting
requirements of this subpart.
Reciprocating Compressor Affected Facility: All reciprocating compressor affected facilities
are those that have a single reciprocating compressor located between the wellhead and
the point of custody transfer is applicable to this subpart. A reciprocating compressor
located at a well site, or an adjacent well site and servicing more than one well site, is not
an affected facility under this subpart. Because the location is a well site, the
reciprocating compressor(s) at the site are not subject to the maintenance practices,
recordkeeping and reporting requirements of this subpart.
Well Affected Facility: The two onsite wells were completed prior to September 18, 2015
4
and were drilled principally for oil, as permitted with the COGCC. Therefore, these
existing wells were not subject to the reduced emissions completions requirements in
OOOO.
40 CFR 60 Subpart 0000a - Standards of Performance for Crude Oil and Natural Gas
Facilities for which Construction, Modification or Reconstruction Commenced After
September 18, 2015: Subpart 0000a regulates certain: well affected facilities (oil and gas
wells); centrifugal compressors with wet seal degassing systems; reciprocating compressors;
continuous -bleed natural gas actuated pneumatic controllers; storage vessels containing crude
oil, condensate, produced water or a mixture thereof, equipment leaks of VOC at natural gas
processing plants; sweetening units at natural gas processing plants; pneumatic pump affected
facilities; and the collection of fugitive emissions components at a well site or at a compressor
station constructed, modified or reconstructed after September 18, 2015. The site is considered a
well site under this regulation.
Storage Vessel Affected Facility: Each storage vessel that emits VOC emissions at or greater
than 6 tons per year (as determined by the maximum average daily throughput) is
subject to the emissions control (95% DRE), recordkeeping and reporting requirements
of this subpart. Legally and practically enforceable limits may be accounted for in
determining VOC emissions from storage vessels for applicability to this subpart. These
storage vessels were constructed prior to September 18, 2015 and are therefore not an
affected facility under OOOOa.
Pneumatic Controller Affected Facility: All continuous bleed pneumatic controllers must be
low or no bleed (≤6 scf/hr natural gas bleed rate). High bleed pneumatic controllers, if
they must be used, are subject to the tagging and reporting requirements of this subpart.
All pneumatic controllers at the site are either intermittent, low (≤6 scf/hr natural gas
bleed rate) or no bleed and as such not applicable to the tagging and reporting
requirements of this subpart.
Reciprocating Compressor Affected Facility: All reciprocating compressor affected facilities
are those that have a single reciprocating compressor located between the wellhead and
the point of custody transfer is applicable to this subpart. A reciprocating compressor
located at a well site, or an adjacent well site and servicing more than one well site, is not
an affected facility under this subpart. Because the location is a well site, the
reciprocating compressor at the site is not subject to the maintenance practices, -
recordkeeping and reporting requirements of this subpart.
Collection of Fugitive Emissions Components: The collection of fugitive emission
components located a well site are subject to a Leak Detection and Repair (LDAR)
program. The facility was constructed prior to September 18, 2015 and was n o t
modified after September 18, 2015. The fugitive emission components are subject to this
subpart.
Well Affected Facility: The reported wells in this application at the State Antelope P-16
Production Facility were completed prior to September 18, 2015 and are not subject to
the reduced completions requirements in 40 CFR 60.5375a.
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existing, new, and reconstructed engines greater than 500 hp at major sources of HAP emissions,
new and reconstructed engines less than 500 hp at major sources of HAP emissions, and new or
reconstructed engines at area sources of HAP emissions.
The facility is an area source of HAP. The Arrow C-101 engines are considered new 4SRB, non -black
start engines. The engines will comply with this subpart by meeting all applicable requirements of
40 CFR Subpart JJJJ [§63.6590(c)(1)].
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