HomeMy WebLinkAbout20203832.tiffCOLORADO
Department of Public
Health Er Environment
Weld County - Clerk to the Board
1150 0 St
PO Box 758
Greeley, CO 80632
December 14, 2020
Dear Sir or Madam:
RECEIVED
DEC 21 2020
WELD COUNTY
COMMISSIONERS
On December 15, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for
Bonanza Creek Energy Operating Company, LLLC - State Antelope J-28. A copy of this public notice
and the public comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.cotorado.gov/cdphe
Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director
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2020-3832
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Bonanza Creek Energy Operating Company, LLLC - State Antelope J-28 - Weld County
Notice Period Begins: December 15, 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, LLLC
Facility: State Antelope J-28
Well Production Facility
SWSW SEC 28 T5N R62W
Weld County
The proposed project or activity is as follows: The applicant proposes to lower throughput through the
condensate and produced water storage 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 13WE2810 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 b Etrvironmertt
Permit number:
Date issued:
Issued to:
COLORADO
Air Pollution Control Division
Department of Public Health El Environment
CONSTRUCTION PERMIT
13WE2810
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 3
Bonanza Creek Energy Operating Company, LLC
State Antelope J-28
123/9BAA
SWSW SEC 28 T5N R62W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
CNDTK 01
003
Twelve (12) 500 bbl above ground fixed roof
atmospheric condensate storage tanks
Enclosed Flare
PWT 01
004
Four (4) 400 bbl above ground fixed roof
atmospheric produced water storage tanks
Enclosed Flare
LPGFL
009
Four 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 this specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. This construction permit represents final permit approval and authority to operate this emissions
source. Therefore, it is not necessary to self -certify. (Regulation Number 3, Part B, Section
III.G.5.)
EMISSION LIMITATIONS AND RECORDS
2. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part
B, Section II.A.4. )
Annual Limits:
COLORADO
Air Pollution Control Division
Page 1 of 10
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO.
VOC
CO
CNDTK-01
003
---
---
1.23
0.4
Point
PWT-01
004
---
---
0.16
---
Point
LPGFL
009
---
1.9
36.0
8.5
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air 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 Pollution 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
Pollutants
Controlled
CNDTK-01
003
Enclosed Flare
VOC and HAP
PWT-01
004
Enclosed Flare
VOC and HAP
LPGFL
009
Enclosed Flare
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
CNDTK-01
003
Condensate Throughput
23,000 BBL
COLORADO
Air Pollution Control Division
Page 2 of 10
PWT-01
004
Produced Water Throughput
25,000 BBL
LPGFL
009
Total Gas Vented From All
Low -Pressure Separators
29.01 MMSCF
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12) month
total. By the end of each month, a new twelve-month total must be 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. AIRS Point 009: The owner or operator must continuously monitor and record the volumetric
flow rate of gas vented from all low pressure separator(s) using the flow meter. The flow meter
must continuously measure flowrate and record total volumetric flow vented from all low-
pressure separators. The owner or operator must use the sum of monthly throughput records
from all low-pressure separators to demonstrate compliance with the limits specified in Condition
5 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. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part
B, Section III.E.) (State only enforceable)
8. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
9. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the
source. During periods of startup, process modification, or adjustment of control equipment
visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive
minutes. Emission control devices subject to Regulation 7, Part D, Sections I.C.1.d or II.B.2.b
shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. Et 4.)
10. 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)
11. This source is subject to Regulation No. 7, Part D, Section I.C General Provisions (State only
enforceable). All condensate collection, storage, processing and handling operations, regardless
of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic
compounds to the atmosphere to the maximum extent practicable. The operator shall comply
with all applicable requirements of Section I.
12. AIRS Point 003 It 004: 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.
13. AIRS Point 003 It 004: 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. AIRS Points 003 and 004: This source is subject to Regulation No. 7, Part D, Section I. the
operator must comply with all applicable requirements of Section I and, specifically, must:
COLORADO
Air Pollution Control Division
a�rrr: ..:e Fi r-:•�rc . v....
Page 3 of 10
• Comply with the recordkeeping, monitoring, reporting and emission control requirements
for 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
• 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 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.
• 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)
15. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section I.C.1. 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, Section 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 I.C.1.e.
16. On or before June 30t'', 2021 (and on June 30t'' each year thereafter), the owner or operator of
oil and natural gas operations and equipment at or upstream of a natural gas processing plant in
Colorado must submit a single annual report that includes actual emissions and specified
information in the Division -approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section V.C.
for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING £t MAINTENANCE REQUIREMENTS
17. AIRS Points 003, 004 and 009: Upon startup of these points, the owner or operator shall follow
the most recent operating and maintenance (OttM) 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 OM 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
18. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
COLORADO
Air Pollution Control Division
Page 4 of 10
ADDITIONAL REQUIREMENTS
19. All previous versions of this permit are cancelled upon issuance of this permit.
20. 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
For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
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.
21. 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, 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
Descri tion
p
pollutant
Emissions - tons per year
Threshold
Current
Permit
Limit
CNDTK 01
003
Condensate
Tanks
VOC
50
37.4
PWT-01
004
Produced
Water Tanks
LPGFL
009
Natural Gas
Venting
COLORADO
Air Pollution Control Division
Page 5 of 10
Note: APEN and permit exempt sources do not have permit limits. However, the PTE of these
sources (excluding fugitives) is still considered in the project increase when evaluating PSD and
NANSR.
GENERAL TERMS AND CONDITIONS
23. 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.
24. 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.
25. 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.
26. 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.
27. 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.
28. 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.
29. 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
COLORADO
Air Pollution Control Division
Page 6 of 10
Permit History
Issuance
Date
Description
Issuance 1
December 19,
2014
Issued to Bonanza Creek Energy Operating
Company, LLC
Issuance 2
June 2, 2017
Removed Point 007 since the emissions are below
APEN thresholds.
Removed 008, 010 and 011 since the points have
been cancelled.
Edited the description of the control device for
Points 003, 004 and 009.
Removed the VRU for Point 009 which increased
emissions and throughput.
Issuance 3
This Issuance
Point 006: Removed since the emissions are below
APEN thresholds and were cancelled.
Point 003: Revised permitted emissions and
throughput based on APEN received July 1, 2020.
Point 004: Revised permitted emissions and
throughput based on APEN received July 1, 2020.
Throughout permit: Updated Colorado Regulation
No. 7 language and citations to version adopted
September 23, 2020.
COLORADO
Air Pollution Control Division
Page 7 of 10
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-reps
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.
N non criteria reportable pollutants In the table aoove with uncontrolled emission rates above 250 pounds
per year (tpy) are reportable and may result in annual emission fees based on the most recent Air Pollution
Emission Notice.
Facility
Equipment ID
ote
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(pound per year)
Controlled
Emissions
(pound per year)
CNDTK-01
003
Benzene
71432
308
15
n -Hexane
110543
1819
91
Toluene
108883
207
10
Ethylbenzene
100414
16
1
Xylenes
1330207
62
3
2,2,4-540841
trimethylpentane
87
4
PWT-01
004
Benzene
71432
175
9
n -Hexane
110543
550
28
LPGFL
All
009
Benzene
71432
3,050
152
n -Hexane
110543
18,279
914
Toluene
108883
2,024
101
Ethylbenzene
100414
244
12
Xylenes
1330207
463
23
COLORADO
Air Pollution Control Division
Page 8 of 10
5) The emission levels contained in this permit are based on the following emission factors:
Point 003:
Pollutant
Emission Factors
Uncontrolled
lb/BBL
Condensate
Throughput
Emission Factors
Controlled
lb/BBL
Condensate
Throughput
Source
NOx
0.0681b/MMBtu
AP -42
CO
0.311b/MMBtu
AP -42
VOC
2.1248
0.1062
EU TANK
n -Hexane
0.0791
0.0040
EU TANK
Benzene
0.0134
0.0007
EEO TANK
Toluene
0.0090
0.0005
EftP TANK
Ethylbenzene
0.0007
0.00004
EftP TANK
Xylenes
0.0027
0.0001
EEO TANK
2,2,4-
trimethylpentane
0.0038
0.0002
MP TANK
Note: The controlled emissions for this point are based on the flare control efficiency of 95%.
A HHV of 2,325 BTU/scf was used for combustion calculations.
Point 004:
Pollutant
Emission Factors
Uncontrolled
lb/BBL Produced
Water Throughput
Emission Factors
Controlled
lb/BBL Produced
Water Throughput
Source
VOC
0.262
0.0131
CDPHE
n -Hexane
0.022
0.0011
CDPHE
Benzene
0.007
0.0004
CDPHE
Note: The controlled emissions for this point are based on the flare control efficiency of 95%.
Point 009:
Pollutant
Weight
Fraction of
Gas (%)
Emission
Factors
Uncontrolled
lb/MMscf
Emission Factors
Controlled
Ib/MMscf
Source
NOx
(lb/MMBTU)
---
0.068
0.068
AP -42
CO
(lb/MMBTU)
---
0.31
0.31
AP -42
VOC
56.7
49,647
2,482.4
Gas Analysis
Benzene
0.12
105.12
5.2561
Gas Analysis
Toluene
0.08
69.781
3.4891
Gas Analysis
Ethylbenzene
0.01
8.4040
0.4202
Gas Analysis
Xylenes
0.02
15.968
0.7984
Gas Analysis
n -hexane
0.72
630.09
31.505
Gas Analysis
Note: The uncontrolled VOC and HAP emissions were calculated using a gas sample collected
9/11/2013 of the gas vented from the low pressure separator at State Antelope J-F-28HNB to
estimate the VOC and HAP content of the stream and a Promax model to estimate stream flow.
Controlled emission factors are based on a flare control efficiency of 95%.
COLORADO
Air Pollution Control Division
Page 9 of 10
Emission factors for CO and NOx are based on AP -42 Table 13.5-1. A HHV of 1,881 BTU/scf was
used for calculations.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this
permit is valid for a term of five years from the date it was received by the Division. A revised APEN
shall be submitted no later than 30 days before the five-year term expires. Please refer to the most
recent annual fee invoice to determine the APEN expiration date for each emissions point associated
with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-
3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAPs
NANSR
Synthetic Minor Source of: VOC
PSD
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
Air Pollution Control Division
Page 10 of 10
Color=ado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
For Division Use Only
Jaclyn Zey
-,32984
?/1/2020
/34/2020
Section 01- Facility Information
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
Type of Facility: Exploration & Production: Weil Pad
What industry segment;Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area? Yes
If yes, for what pollutant? Ozone (NOx & VOC). •
Bonanza Creek Energy Operating Company, ti_C
123
$3A
to Antelope J-28 :!
Weld County
Section 02 - Emissions Units In Permit Application
Leave Blank - For Division Use Only
AIRS Point #
(Leave blank unless
APCD has already
assigned)
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
(Leave blank unless
APCD has already
assigned)
Issuance
#
Self Cert
Required?
Action
Engineering
Remarks
003
Storage Tank
CNDTK-0'E
Yes
S?'x=2810
3
No
Permit
Modification
004
Storage Tank
PWT-G2
Yes
134JE7_II10
3
No
Perif
Modification
Quadrant
Section
Township
Range
SWSW
28
5N
62
Section 03 - Description of Project
This modification permits revised err,
following changes were made to the
1. Removed all permit
cancelled.
2. Updated Co
to be consisten
iations and conditio
3. Included Colorado Regulat+on Numbe
dp Regulation No. 7 long e t
t1 recently issued per
ghput limits for tit
related to loadout
5hdensate(AIRS
nd produced w;
s (AIRS ID 004). >≤`dditfona{iy, the
S ID 006) as the emissions from the point dropped below thesholds. and the point has been
hroughout perm{ to version of rule adopted x(23/2020 and modified .conditions that teferen=
ection V
de inventory requi
tits. Section V reau.re=;tents'did not ex
Sections 04, 05 & 06 - For Division Use Only
Section 04- Public Comment Requirements
Is Public Comment Required?
If yes, why? :Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requiremer
Was a quantitative modeling analysis required? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Yes
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ Q ❑ ❑
Title V Operating Permits (OP) ❑ ❑ ❑ M ❑ ODE
Non -Attainment New Source Review (NANSR) ❑ 0
Is this stationary source a major source?
Colorado Air Permitting Project
If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) Y ❑ 00000
Title V Operating Permits (OP) 0000 ❑ 000
Non -Attainment New Source Review (NANSR) ; ❑ ❑
Section 01 -Administrative Information
'Facility AIRs ID:
County
Plant
Point
Section 02 -Equipment Description Details
Storage Tank Liquid
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Throughput=
Potential to Emit (PTE) Condensate Throughput =
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per BBL of liquids
produced =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
s Barrels (hbl) per year
;Barrels (661) per year
Barrels (bbl) per year
Btu/scr
cf/bbl
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Control Device
2541 MMBTU per year
1,511.2 MMBTU per year
..4_..2 MMBTU per year
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Pollutant
Uncontrolled
Controlled
(Ib/bbl)
(Ib/bbl)
(Condensate
Throughput)
(Condensate
Throughput)
Emission Factor Source
Pollutant
• tIll IIMMIr
Immno
0. 8^timi
Control Device
Uncontrolled
(Ib/MMBtu)
(waste heat
combusted)
Uncontrolled
(lb/bbl)
i
Emission Factor Source
Pollutant
Uncontrolled
Uncontrolled
(Pilot Gas Heat
Combusted)
ZEEIMIIIII
MINNEIllt.,,.^v{100E
MINIMEEh S4
0 ,0C -
(Pilot Gas
Throughput)
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
0.3
0 _
7.
�
..0
0.2
0.1
14.2
24.4
c
..r
2t€
.1.2
?ORD
=0.4
0.2
0.2
, .
000-0
27.5
' Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
305,2.
51.33
_,"
30 8,3,
15.-
207.3
34.5
1,7
207._
_0.4
15.1
2.'=
01
16._
0.ti
3 of 12
KAPA\2013\13W E2810.CP3
Emissions inventory
xyiene
n -Hexane
224 TMP
10.4
106.0.
74.7
1€19.3
37.4.
51,0
0.7
4 of 12 ICAPA\2013\13WE2810.CP3
StOrav Tank() Elf: slow; Inventor'y'
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
NOt ,nough s,f-or,,,or,
Regulation 7, Part D,Section I.C, D, E, F
Storage tank is suitinct to Regulasion 7, Part D Section' it s
Regulation 7, Part D,Section I.G, C
Storage Tank is .rot 'enact to Regulation 7 Section 1.6
Regulation 7, Part D,Section II.B, C.1, C,3
St . oubl t Regulation 'a, Section it B, C.1 3 =.3
Regulation 7, Part D,Section II.C.2
Storage Rink is subiect to Regulation 7, Part D, Sectloa'1 C 1
Regulation 7, Part D,Section II.C.4.a.(i)
Storage Tank is not ai Hiatt to Regulation 7, Part D. 5estien'I C...71
Regulation 7, Part D,Section II.C.4.a.(ii)
Storage Tank is not subject to Regulation ?, Par! D. Sesti ; t'I.C.z aill7
Regulation 6, Part A, NSPS Subpart Kb
Storage T=nk,s riot su 5;S:a tc t‘IS.S hob
Regulation 6, Part A, NSPS Subpart OOOO
starage Teak la eel wc•rct to ` VPS OOO+"•
NSPS Subpart 0000a
:tozzge tank is art s..b,e.t to 745PS 0OOOa
Regulation B, Part E, MACE Subpart HH
Storage rank is not s,.b;vct to MACP' KH
(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 drown 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 guideline
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Section 08 -Technical Analysis Notes
Section 09 -SCC Coding and Emissions Factors (For Inventory Use Only).
AIRS Point #
Process #
O1
SCC Code
Uncontrolled
Emissions
Pollutant Factor Control% Units
PM30 .. lb/1,000 gallons Condensate throughput
PM2.5VI 52, lb/1,000 gallons Condensate throughput
50x : ^r lb/1,000 gallons Condensate throughput
NOx .:18 _ lb/1,000 gallons Condensate throughput
VOC Y: .;: .. lb/1,000 gallons Condensate throughput
CO le; Ih/1,000 gallons Condensate throughput
Benzene . 37 -., lb/1,000 gallons Condensate throughput
Toluene 0a". 95 lb/1,000 gallons Condensate throughput
Ethylbenzene _ lb/1,000 gallons Condensate throughput
Xylene 5:et ._ lb/1,000 gallons Condensate throughput
n -Hexane 16S .. lb/1,000 gallons Condensate throughput
224 TMP ,.U; .. lb/1,000 gallons Condensate throughput
5 of 12 KAPA\2013\13WE2810.CP3
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
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 on
2. grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
IYou have indicated that source is in the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY (Regulation 3, Part A, Section II.D.1.a)?
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 on
2. grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
INot enough information
Colorado Regulation 7, Part D, Section I.C-F & G
1. Is this 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 I.A.1)?
2. Is this storage tank located at oil and gas operations that collect, store, or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processin
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 1.G.2)?
6. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year VOC (Regulation 7, Part D, Section I.D.3.a(ii))?
'Storage tank is subject to Regulation 7, Part D, Section I.C-F
Source is in the Non -Attainment Area
Part D, Section I.C.1 —General Requirements for Air Pollution Control Equipment— Prevention of Leakage
Part D, Section I.C.2— Emission Estimation Procedures
Part D, Section I.D— Emissions Control Requirements
Part D, Section I.E— Monitoring
Part D, Section I.F— Recordkeeping and Reporting
Y
;v
N
Storage Tank is not subject to Regulation 7, Section I.G
Part D, Section I.G.2 - Emissions Control Requirements
Part D, Section I.C.l.a and b — General Requirements for Air Pollution Control Equipment— Prevention of Leakage
Colorado Regulation 7, Part D, Section II
1. Is this storage tank located at a transmission/storage facility? ,y
2. Is this storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station' or natural gas processing plant° (Regulation'/
3. Does this storage tank have a fixed roof (Regulation 7, Part D, Section II.A.20)?
4. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year VOC (Regulation 7, Part D, Section II.C.1.c)?
'Storage tank is subject to Regulation 7, Part D, Section 11, 8, C.1 & C.3
Part D, Section II.B— General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Part D, Section 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 II.C.2.b)? N
'Storage tank is subject to Regulation 7, Part D, Section 11.0.2
Part D, Section II.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
Is the controlled storage tank located at a well production facility, natural gas compressor station, or natural gas processing plant constructed on or after May 1, 2020 or located at a
6. facility that was modified on or after May 1, 2020, such that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon
'Storage Tank is not subject to Regulation 7, Part D, Section ILC.4.a(l)
Is the controlled storage tank located at a well production facility, natural gas compressor station, or natural gas processing plant constructed on or afterJanuary 1, 2021 or located at
7. a facility that was modified on or afterJanuary 1, 2021, such that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon N
• 'Storage Tana is net subject to Regulati=on 7, Part D, Section li.C.4.a(i), b - f
40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m) [-472 BBLs] (40 CFR 60.110b(a))?
2. Does the storage vessel meet the following exemption in 60.111b(d)(4)?
a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 (-10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfe
3. Was this storage Vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984 (40 CFR 60.110b(a))?
4. Does the tank meet the definition of "storage vessel"' in 60.111b? ri
5. Does the storage vessel store a "volatile organic liquid (VOL)"' as defined in 60.111b?
6. Does the storage vessel meet any one of the following additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa [^29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or
b. The design capacity is greater than or equal to 151 m3 (-950 BBL] and stores a liquid with a maximum true vapor pressure' less than 3.5 kPa (60.110b(b))?; or
c. The design capacity is greater than or equal to 75 M3 (-472 BBL] but less than 151 m3 [-950 BBL] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(6(
7. Does the storage tank meet either one of the following exemptions from control requirements:
a. The design capacity is greater than or equal to 151 m3 (-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
b. The design capacity is greater than or equal to 75 M3 (-472 BBL] but less than 151 m3 (-950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal
Storage Tank is not subject to NSP5 Kb
40 CFR, Part 60, Subpart OOOO/OOOOa, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
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
1. industry?
2. Was this storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?
3. Was this storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after September 18, 2015?
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 60.5430/60.5430a?
6. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH?
ISt wage Tank is not subject to NSPS OOOO
[Note: If a storage vessel is previously determined to be subject to NSPS OOOO/OOOOa due to emissions above 6 tons per year VOC on the applicability determination date, it
should remain subject to NSPS OOOO/OOOOa per 60.5365(e)(2)/60.5365a(e)(2) even if potential VOC emissions drop below 6 tons per year)
40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities
1. Is.the storage tank located at an oil and natural gas production facility that meets either of the following criteria:
a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR
A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is
b. delivered to a final end userz (63.760(a)(3))?
2. Is the tank located at a facility that is major 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 63.761?
5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart OOOO?
'Storage Tank €s not subject to iirlAcT H
Subpart A, General provisions per §63.764 (a) Table 2
§63.766 - Emissions Control Standards
§63.773 - Monitoring
§63.774 - Recordkeeping _
§63.775 - Reporting
RACT Review
RACT 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
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control
Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual
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 will control. The use of non -mandatory language such as "recommend,"
"may,""should,"and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required"are
intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not
Storage Tanit(s) Emissions inventory
Section 01- Administrative Information
Facility AIRs ID:
gorgom, 6f.....,
County Plant
Po
Section 02 - Equipment Description Details
Storage Tank Liquid
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control Efficiency °:
Limited Process Parameter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tmrk(s)
Actual Throughput=
Requested Permit Limit Throughput=
,,., ;;S;T2 Barrels bbl) per year
%Barrels(bbl) per year Requested Monthly Throughput=
Barrels (bbl) per month
Potential to Emit (PTE) Condensate Throughput=
Secondary Emissions - Combustion Device(s)
Heat content of waste gas =
Volume of waste gas emitted per BBL of liquids
produced =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
Barrels (hbl) per year
Potential to Emit (PTE) heat convent of waste gas routed to combustion device =
Control Device
20.0).6 MMBTU per year
1.34E4 MMBTU per year
1.351.. = MMBTU per year
Section 04- Emissions Factors& Methodologies
Will this storage tank emit flash emissions?
Section 05 - Emissions Inventory
0,0-8C
U3`00
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year] (tons/year)
Requested Monthly Limits
' 'Controlled
)Ibs/month)
PM10
PM2.5
50x
NOx
CO
"._
0.0
0,0
0.0
0.0
.:._
0.0
0.0
00
.....
0.0
0.0
0.0
0.0
0-1
; _
0.0
0.0
0.2
0.2
35..
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
Obs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
IMO
35.0
1.8
525
�-
0,0
_ Q0
0,0
0.0
0.0
0:0
JO
s;-0
0.0
C,.
8 of 12 KAPA\2013\13WE2810.CP3
Storage T a sJ Emissions Inventory
xyiene
n -Hexane
224 TMP
0.0
0.0
9 of 12 KAPA\2013\13WE2810.CP3
St.)rage Tan K(ji Er:, ,Si_vv.; Inventor,
Section 06- Regulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7, Part D,Section I.C, D, E, F
Storagit tank :5 s,•n;ect to Reggrat,orr ? Pgrt D. 5ect,oc' G-
Regulation 7, Part D,Section I.G, C
Stoosee rage •s oot subjett to Rep iao ? Seet'.:r I.G
Regulation 7, Part D,Section II.B, C.1, C.3
..,raye.91,. s s.m,:.: to Reg.<.._.n 7Bart D S ttge,•, B. C.1 B_ '
�
Regulation 7, Part D,Section II.C.2
,tt- ao0.,s,..h.ect to Regu'at:,r.; 7, Barns Sert: n'LCt
Regulation 7, Part D,Section II.C.4.a.(i)
Storage sa sk :s -et st:o;=a to Regaraae;; z ?art'. See : I "1.4 -at:`
Regulation 7, Part D,Section ll.C.4.a.(ii)
Storage - .s gtsto mtgs.. to Seg ; ita, r Part : e,.ct., ,.:.C.4a .e Z.
Regulation 6, Part A, NSPS Subpart Kb
Storage 'ark .5 1...t -..g„ect t. StStti 51s
Regulation 6, Part A, NSPS Subpart OOOO
sc.. :agt I.i., al..,..., Y.,._Pc.00,.;
NS PS Subpart OOOOa
to:age tre•;,'..r,;. esos.st re NSge trim.„,
Regulation 8, Part E, MACT Subpart HH
(See regulatory applicability worksheet for detailed analvsisl
orocu.eq 7u stet. Stet seat t;ar.r?s 0;w;,.gtr,;r•,• MAi.r.tn
Section 07 Initial and Periodic Sampling and Testing Requirements
For condensate or crude oil tanks, does the company use the state default emissions factors to
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 inPSMemo 14-03.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Section 08- Technical Analysis Notes
Section 09 -SCC Coding and Emissions Factars (For Inventory Use Only)
AIRS Point #
Process #
01
SCC Code
Uncontrolled
Emissions
Pollutant Factor Control% Units
PM10 tat lb/1,000 gallons Produced Waterthroughput
PM2.5 lb/1,000 gallons Produced Water throughput
5Ox lb/1,000 gallons Produced Water throughput
NOx lb/1,000 gallons Produced Water throughput
VOC lb/1,000 gallons Produced Water throughput
COQ lb/1,000 gallons Produced Water throughput
Benzene .. .. lb/1,000 gallons Produced Water throughput
Toluene t lb/1,000 gallons Produced Water throughput
Ethylbenzene 5, lb/1,000 gallons Produced Water throughput
Xylene 4 40- r lb/1,000 gallons Produced Water throughput
n -Hexane ,5 15 16/1,000 gallons Produced Water throughput
224 TMP lb/1,000 gallons Produced Water throughput
10 of 12
le\PA\2013\13WE2810.CP3
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and B - APEN ancrPermit Requirements
Source is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.l.a)?
2. Produced Water Tanks have no grandfathering provisions
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
IYou have indicated that source is in the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Produced Water Tanks have no grandfathering provisions
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
'Source requires a permit
Ui
Colorado Regulation 7, Part D, Section I.C-F & G
1. Is this 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 I.A.1)? Y
2. Is this storage tank located at oil and gas operations that collect, store, or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processing
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 I.G.2)?
6. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year VOC (Regulation 7, Part D, Section I.D.3.a(ii))?
N
'Storage tank is subject to Regulation 7, Part D, Section I,a_z
Part D, Section I.C.1 — General Requirements for Air Pollution Control Equipment— Prevention of Leakage
Part D, Section I.C.2— Emission Estimation Procedures
Part D, Section I.D — Emissions Control Requirements
Part D, Section I.E— Monitoring
Part D, Section I.F— Recordkeeping and Reporting
Storage Tank _- `ion 7, Section I.G
Part D, Section I.G.2 - Emissions Control Requirements
Part D, Section I.C.l.a and b — General Requirements for Air Pollution Control Equipment — Prevention of Leakage
Colorado Regulation 7, Part D, Section II _
1. Is this storage tank located at a transmission/storage facility? `d
2. Is this storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station3or natural gas processing plant (Regulation "!
3. Does this storage tank have a fixed roof (Regulation 7, Part D, Section II.A.20)? 1
4. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year VOC (Regulation 7, Part D, Section II.C.1.c)?
Storage tank is subject to Regulation 7, Part D, Se , C.1 & C.3
Part D, Section II.B— General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Part D, Section 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 II.C.2.b)?
'Storage tank is subject to Regulation 7, fart D, Section Ii.C.2
Part D, Section II.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
Is the controlled storage tank located at a well production facility, natural gas compressor station, or natural gas processing plant constructed on or after May 1, 2020 or located at a
6. facility that was modified on or after May 1, 2020, such that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon N
ISterage Tank is not sus, r wn 7, Part 0, Section
Is the controlled storage tank located at a well production facility, natural gas compressor station, or natural gas processing plant constructed on or after January 1, 2021 or located at
7. a facility that was modified on or after January 1, 2021, such that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon N
'Storage `Sank is not subject to Regulation, 7, Part D, Section II.C.4,a:; '' - .
40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m3) (-472 BBLs) (40 CFR 60.110b(a))?
2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? _
a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 ['"10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfe
3. Was this storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984 (40 CFR 60.110b(a))? _
4. Does the tank meet the definition of "storage vessel"3 in 60.111b? _
5. Does the storage vessel store a "volatile organic liquid (VOL)"sas defined in 60.111b? _
6. Does the storage vessel meet any one of the following additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa ["29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or
b. The design capacity is greater than or equal to 151 m3 [-950 BBL] and stores a liquid with a maximum true vapor pressure' less than 3.5 kPa (60.110b(b))?; or
c. The design capacity is greater than or equal to 75 M3 (-472 BBL] but less than 151 m3 (-950 BBL] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(6(
7. Does the storage tank meet either one of the following exemptions from control requirements:
a. The design capacity is greater than or equal to 151 m3 (-950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but lessthan 5,2 kPa
b. The design capacity is greater than or equal to 75 M3 (-472 BBL] but less than 151 m3 ["'950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal
Storage Tank is not subject to NSPS Kb
N
40 CFR, Part 60, Subpart OOOO/OOOOa, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
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
1, industry?
2. Was this storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?
3. Was this storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after September 18, 2015?
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 60.5430/60.5430a?
6. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH?
(Storage Tank is not subject to MPS OOOO
[Note: If a storage vessel is previously determined to be subject to NSPS OOOO/OOOOa due to emissions above 6 tons per year VOC on the applicability determination date, it
should remain subject to NSPS OOOO/OOOO2 per 60.5365(e)(2)/60.5365a(e)(2) even if potential VOC emissions drop below 6 tons per year]
40 CFR, Part 63, Subpart MALT HH, Oil and Gas Production Facilities
1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria:
a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR
A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is
b. delivered to a final end userz (63.760(a)(3))?
2. . Is the tank located at a facility that is major' for HAPs?
3. Does the tank meet the definition of "storage vessel"4 in 63.761? ,
4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"5 per 63.761?
5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart OOOO?
'Produced Water Storage tank is not subject to MAU HH
Subpart A, General provisions per §63.764 (a) Table 2
§63.766 - Emissions Control Standards
§63.773 - Monitoring
§63.774 - Recordkeeping
§63.775 - Reporting
RACT Review
RACT 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 •
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control
Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual
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 will control. The use of non -mandatory language such as "recommend,"
"may," "should," and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are
intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not
S4
June 30, 2020
Stefanie Rucker
Colorado Department of Public Health and Environment
Air Pollution Control Division, APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Boma
CREEK
410 17th Street, Suite 1400
Denver, CO 80202
(720) 440-6100 phone
(720) 305-0802 fax
RE: Permit Modifications — CNDTK & PWT
Cancellation Request — TLO
State Antelope J-28 Production Facility (COGCC #431937, 123/9BAA)
Bonanza Creek Energy Operating Company, LLC
Weld County, CO
Ms. Rucker,
10,e
v
This APEN Update package is being re -submitted with the required signatures as requested in the
rejection letter from Byron Caton on 6/17/2020.
Bonanza Creek Energy Operating Company, LLC (BCEOC) is pleased to submit the attached APENs and
supporting documentation for the condensate storage tanks (CNDTK-01, AIRS Point 003) and produced
water storage tanks (PVVT-01, AIRS Point 004) at the State Antelope J-28 Production Facility (COGCC
#431937, 123/9BAA). Also attached is an APEN cancellation request for the truck loadout (Truck Loadout,
AIRS Point 006).
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
l'aw•ars.-ITE 0110CE
410 I"' Suvar. Suite /400
Denver, CO 8010?
Office 0201440-6101
Form APCD-100
ICOLORADO
Department of Public
Health b 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 J-28 Production Facility (COGCC# 431937, AIRS ID 123/9BAA)
April 2020
Are you requesting a facility wide permit for multiple emissions points?
Yes No
`• ❑
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
a
❑
B
Air Pollutant Emission Notice(s) (APENs) &
Application(s) for Construction Permit(s) — APCD Form Series 200
❑
0
C
Emissions Calculations and Supporting Documentation
•
■
D
Company Contact Information - Form APCD-101
El
■
E
Ambient Air Impact Analysis
■
•
P I Check here if source emits only VOC (Attachment E not required)
F
Facility Emissions Inventory — Form APCD-102
d
❑
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
❑
r- Check here if single emissions point source (Attachment G not required)
H
Operating & Maintenance (O&M) Plan — APCD Form Series 300
0
❑
® Check here if true minor emissions source or application is for a general
permit (Attachment li not required)
I
Regulatory Analysis
d
❑
nCheck here to request APCD to complete regulatory analysis
D (Attachment I not required)
J
Colorado Oil and Gas Conservation Commission (COGCC) 805 Series Rule
Requirements— Form APCD-105
I��' 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-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Check box if facility is an existing Title V source: n 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 Form APCD- 100-AppCompleteChecklist-Ver l 1-29-2012 docx
Bonanza Creek Energy Operating Company, LLC. - State Antelope J-28 Production Facility (COGCC 0431937)
Condensate Tank Site Specific Emission Factor Calculations
Emission Source: Condensate Tanks
Designed Throughput: 10.60 bbl/day
Designed Throughput: 3,868 bbl/yr
Requested Throughput: 23,000 bbl/yr
Enclosed Flare VOC Control Efficiency: 95%
Operating Days per Year: 365 days/yr
Total Emissions
Pollutant
Emission Factors (')
(Iblbbl)
Actual Emissions (tpy) (e)
Requested Emissions (tpy)(*)
Uncontrolled
Controlled
Uncontrolled
I Controlled
VOC
212
4.11
0.21
24-44
1.23
Benzene
0.0134
0.026
_—_
0.0020
0.155 ti
0.008
Toluene
0.0090
0.017
0.0010
0.104
0.006
Ethylbenzene
0.0007
0.0014
i
0.0010
0.009
0.001
Xylenes
0.0027
0.005.
0.0010
0.032
0.002
- _
n -Hexane
0.0791
-
0.15
^,
i
0.008
0.910
0.046
224-TMP
0.0038
0.007
0.0010
0.044
0.003
Notes:
(a) Emission Factors from Permit e13wE2810 (2. issued June 2 2017
(b) Potential to Emit (tpy) _ (Emission Factor, Ib/bbl) • (PTE Throughput, bbl/yr) / (2,000 lb/ton)
(c) Requested Emissions (tpy) _ (Actual Emissions, tpy)
(d) Controlled and Uncontrolled Actual Emissions calculated from 2010 production data and previously established emission factors
Bonanza Creek Energy Operating Company, LLC. - State Antelope J-28 Production Facility (COGCC 0431937)
Enclosed Combustion Device (ECD) Emission Calculations for Condensate Tank Battery 1
Emission Source:
Condensate Tanks
Source Type:
ECD
Heat Input Requested:
0.29 MMBtu/hr
Heat Input Actual:
0.15 MMBlu/hr
. Gas Oil Ratio (GOR):
28.26 scf/bbl
Tank Vent Gas Flowrate Requested:
74.2 scf/hr
Tank Vent Gas Flowrate Requested:
0.65 MMscf/yr
Tank Vent Gas Flowrate Actual:
12.5 scflhr
Tank Vent Gas Flowrate Actual:
---_--_.. .-......_..-____--
Pilot Gas Flowrate:
0.11 MMsd/yr
16.8 scf/hr
Pilot Gas Flowrate:
Total Combustors On Site:
0.15 MMscf/yr
3
-
_
Total Flowrate to Combustor Including Pilot:
0.55 MMscf/yr
Estimated HHV:
2,325 Btu/scf
Total VOC Control Efficiency:
95%
0.0020 gr/scf
Sulfur Content of Fuel:
Operating Hours per Year:
8,760 hr/yr
Pollutant
Emission Factors or
Uncontrolled Emissions (')
Actual Emissions
Requested Emissions
lbIhr D4 I')
tpy Di)
Ib/hr (N. (e)
tpy (e)
CO,
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N2O
N/A
N/A
N/A
NO„
0.068 Ib/MMBtu
0.01
005
0.0000
0.0008
0.05
0.02
0.09
_.0.40
CO
0.3101b1MMBtu
0.20
0.0002
0.0034
0.09
._ -------•
0.0001
0.0024 ;
- --
SO2
PMta
_.___. ----
0.00025 Ib/MMBtu
40.0 • P9 / t
0 0004
0.0106
PM2 s
40.0 pg /I
0.0008
0.0034
0.0024 !
0.0106
Notes'
(a) Emission factors are from AP -42 Tables 13.5-1 8. 2 (Industrial Flares)
40 pg / L is for lightly smoking flare (this is conservative as this unit is smokeless in design).
SO) emissionsbased on AP42, which is based on 100% conversion of sulfur to SO at 2000 grains/MMscf.
(b) Hourly Emission Rate (lb/hr) except for PM ,o = (Emission Factor. Ib/MMBtu)' (Heat Input. MMBtu/hr)
(c) (set CH./hr) (10.6 scf &sof CH 4 (0.0283 m'lscf E) (40 p PM tall E) (1000 I/m3) (g; lff pg) (lb/453.59 g) / (hr/yr) = lb PM,/, / hr
(d) Annual Emission Rate (toy). (Hourly Emission Rate, Ib/hr) • (hr/yr) / (2.000 lb/ton)
Bonanza Creek Energy Operating Company, LLC. - State Antelope J-28 Production Facility (COGCC #431937)
Produced Water Tank Site Specific Emission Factor Calculations
Emission Source: Produced Water Tanks
Designed Throughput: 13.72 bbl/day
Designed Throughput: 5,006 bbl/yr
Requested Throughput: 25,000 bbl/yr
Enclosed Flare VOC Control Efficiency: 95%
Operating Days per Year: 365 days/yr
Tank Emissions
Pollutant
Emission Factors D
(lb/bbl)
Actual Emissions
(tpy) (d)
Requested Emissions (tpy) (`)
Uncontrolled
Controlled
Uncontrolled
Controlled
NOx
0.0036
0.01
0.05
CO
0.0166
0.04
0.21
VOC
0.2620
0.66
0.03
3.28 0.16
Benzene
0.0070
0.018
0.001
0.088 0.005
n -Hexane
0.0220
0.056
0.003
0.275 0.014
Notes:
(a) Emission factors based on CDPHE emission factors for Weld County
(b) Requested Emissions (tpy) _ (Actual Emissions, tpy)
(c) Uncontrolled Emissions (tpy) _ (Emission Factor, lb/bbl)' (Actual Throughput, bbl/yr) / (2,000 lb/ton)
NOx and CO emission Factors Derived from CDPHE PS Memo 09-02 and AP -42 emission, factors of 0.31 Ib/MMBtu for CO and 0.068 lb/MMBtu for NOx
Sample Calculation: 1496 (Btu/scf) x 36 (scf/bbl) / 1X106 (Btu/MMBtu) X 0.31 (lb CO/MMBtu) = 0.0166 lb/bbl CO
Bonanza Creek Energy Operating Company, LLC. - State Antelope J-28 Production Facility (COGCC 8431937)
VOC Emissions from Truck Loading (AP -42 Chapter 5.2 (1/98)]
Site
Product
Loading Mode
Sates
Saturation
Factor
(S) I')
True Vapor
Pressure (P)
[psia]
Molecular
Weight (M)
[lb/lb-moll
Bulk Temp.
(T) [F]
Vapor VOC
Content (C)
(wt %I
Uncoatroned
Loading Loss
(LEI lb)
[lblbbl]
Uncontrolled
VOC Emissions
Collection
Efficiency (')
IN
Control
Efficiency
[9t,]
Controlled
VOC
Emissions
State Antelope J-28
Condensate
Submerged loading.
dedicated normal service
(default)
3,868 bbl/year
0,6
N/A
N/A
64
100.00%
0.236
0.46 tpy
100.0%
0.0%
0.46 tpy
(a) Source: AP -42 Table 5.2-1 (1/95)
(b) Equation 1 for loading losses: (C)' (12.46) ' (SPM / T)W - L_
Where:
4 = loading losses, Ibs/1000 gal of liquid loaded
S = saturason factor
P = true vapor pressure of Squid loaded (psia) based on regression analysis for crude oil (AP 42 Chapter 7.1 page 56) and a raid vapor pressure of 7.9 psia
M = true vapor pressure of Sgwd loaded (ibAb-mole) based on intepolation of Table 7.1-2 of AP 42 and a raid vapor pressure of 7.9 psia
T = temperature of bulk liquids loaded 'R (°F = 460) from EPA TANKS Meteorological Database for Denver, CO
of
(c) Based on all tanker trucks having 70% (Basic) and the collection ef6edencies in AP 42 Chapter 5.2, page 5.2-6
AP -42 Chapter 5.2, Table 5.2-1 (1/95)
Submerged loading of a dean cargo tank
0.5
Submerged loading:. dedicated normal service (default)
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 vessels Submerged loading: ships
0 2
Submerged loading' barges
0.5
Vapor Methane
Content (C)
[wt %]
Uncontrolled
Loading Loss
(Lt) (b)
[lb/1,000-gall
Uncontrolled
Methane
Emissions
Collection
Efficiency i`)
['k]
Control
Efficiency
[°k]
Controlled
Methane
Emissions
0.00%
0.00
0.0 tpy
70.0%
1.0%
0.0 tpy
HAP
Wt. % of
THC (°)
Loading Loss
lb/bbl (4
Uncontrolled HAP Emissions (')
Controlled HAP Emissions I')
Benzene
__.
n -Hexane
0.1737%
1.5254 k
0.000410
0.00360
1.591b/yr
13.921b/yr
_
0001,tpy
0.007 tpy
1.59 lb/yr
13.92 lb /yr
0.001 toy_
i 0.007 tpy
Total
15.51 tpy
0.01 tpy
15.51 tpy
I 0.01 tpy
(d) Based on Condensate Composition
(e) HAP Emissions, tpy = (VOC Egressions, tpy) ' (HAP W[. % of THC)
(1) Iblbbi Emission Factors from CDPHE
Form APCD-101
COLORADO
Department of Public
I Health & Environment
Company Contact Information Form
Ver. September 10, 2008
Company Name: Bonanza Creek Energy Operating Company, LLC (BCEOC)
Source Name: State Antelope J-28 Production Facility (COGCC# 431937, AIRS ID 123/9BAA)
Permit
Contact':
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
B(Permit
(Permit Fees)3
tF es?
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':
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 Fees)'
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: ri
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.
2 The compliance contact should be the point of contact for discussing inspection and compliance at the permitted
facility.
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)
4 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-lnformation (21.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-I02
Company Name: Bonanza Crock Energy Operating Common LL('
Source Name: State Antelope J-2% Production Focilitl (COGCC 0431437,
Source AIRS ID: t23-9BAA
Colorado Department of Public Health and Environment
Air Pollution Control Division
Facility Wide Emissions Inventory Form
Ver. April, 2015
Uncontrolled 1 otenOd t, Emit WHO
(handled Potential fa End, (ME.)
Criteria (II I) I I2AIM dbxryrl
(.dterl. Yl') I HAIAMseyr)
(T
AlRh 11)
EnruPrrrenl lkvripOmr
TAP
PM10
1'\12.5
6101
NHr
Clet'
I
CO III( 31H
Aceol
Acro
R!
Td
FR
Xyi
n-Hea
Merh
224-T811'
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tilll
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I
CO IHt'HU
Aental
Arm
RI,
Td
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Ayt
roller
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224411P
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3,050
2.020
244
404
10,200
8
114
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160
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154
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14
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58
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AYF.N Only - Permit Exempt hourrea
0.0
0.1
0.1
00
7.3
]48.6
12.1 I 0
53
50
3,308
2,071
247
468
19,136
58
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0.0
0.5
0.5
0.0
3.0
38.1
10.9 I 0
1,1
50
196
114
IS
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457
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APE::N 1. hdy Wht.''r
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00
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-
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-
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-
02
121 -!+HM -1017
131,311 a E:Oullmarl Leaks
_
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'
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(1
Insignificant. Subtotal.
Total, All towns/t'
0.0
9.1
0.1
0.0
IJ
6.9
I.l 2
0
6
75
22
4
10
349
0
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0.0
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22
4
l0
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0
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I'oc+ntrdled HAN Summar,
I ncontr llal total. AII IIA Pe
('rmtndled 81.15. Summery
Controlled Teed MI HAN
tTP1)-4 0..0 I 0.0 I 8.0 I 1.7 I 1.0 I a.l I 0.2 1 1.7 I •.0 I 0.0 I
(14111.1 WO I 0.0 I 0.0 I 0.1 I 0.l I 0.0 I 0.0 1 0.7 I 0.0 I OA
ars i = 11.9
(TP1) 4=11
Footnotes:
I llns form should be completed to include both existing sources and all proposed new in modifications to existing emissions sconces
1 lithe ennsslml5 source is neu then enter "proposed" under the Permit No. and AIRS ID data columns
?. HAP abbreviations include:
BE Benzene -
Tol= Toluene
EB -- Ethclbenenc
Xyl>4lene
HCHO = Fmmaldehs de
4 APEN Exempt/Insignificant Sources should be included when nnrranted.
224•TMP ^= 2.2.4-Tomodo Ipcntane
Metal = Acclaldchpde
Acre Acrolcin
maea = n-HeNane.
Meth Methanol
�4
BonAnzn
CREEK
Process Description
State Antelope J-28 Oil & Gas Production Facility
The State Antelope J-28 Production Facility (COGCC #431937) 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 four wells, State Antelope J-F-28HNB, State Antelope E14-A11-28HNB, State
Antelope 14-11-28HNB, and State Antelope J14-F11-28HNB.
The following equipment and emission sources are on site:
• One (1) DOOSAN D081 NA Electric Generation Engine;
• Twelve (12) Condensate Oil Tanks (12 @ 500bb1);
• Four (4) Produced Water Tanks (4 @ 400bb1);
• Four (4) Produced Water Vaults (4 @ 59bb1);
• Four (4) Heated Separators (0.75 MMBtu/hr capacity);
• Three (3) Leed Fabrication L30-0100, 48" ECDs;
• Low Pressure Gas Flaring;
• Compressor Blowdowns;
• Fugitive Equipment Leaks;
• Pneumatic Devices; and
• Truck Loading Operation.
Gas and oil produced from the wells is processed through the high pressure separators where liquids are
separated from the natural gas. The liquids are then sent to the low pressure separator where the oil and
water are separated. The water is sent to the produced water tanks before being trucked from the facility.
The oil is sent to the storage tanks onsite.
All oil is trucked from the facility. Truck loading vapors are uncontrolled. The overhead gas from the low
pressure separators is sent to the three (3) enclosed combustors for control.
Flashing, working and breathing loss vapors from the oil tanks and the water tanks are routed to the
enclosed combustors. The enclosed combustors have a vendor guaranteed destruction efficiency of 98°/0
or higher, with an overall collection and control efficiency of 95%.
Finally, each separator burner, fugitive emission, concrete water vault, compressor blowdown, truck
loadout and pneumatic device is an APEN exempt emission source having less than 2 tons per year of
any single pollutant and/or 1 tons per year of VOC or NOx (the facility is located within the nonattainment
8 -hour Ozone Control Area).
,r#
High/Low
Pressure
Separators
Ci+tc Storage ant,
State Antelope J-F-28HNB
State Antelope E14-A11-28HNB
State Antelope 14-11-28HNB
State Antelope J14-F11-28HNB Wells
State Antelope I-28 Production Facility
SW Y. SW % Sec. 28, TSN, R62W
Weld County, Colorado
—tl
Water Trucked Out
Oil Truck loadout
V4
eonnnzn
CREEK
CDPHE
COLORADO
Air Pollution Control Division
Department of Public Health 8 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 oam Plan may be used for multiple tanks at one facility if each are controlled and monitored in
the same manner.
An OEtM Plan shall be submitted with the permit application when required. The facility operator must comply
with the requirements of the Oa 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 O&M Plan until an approval letter is issued for the new OEtM Plan.
The operator is required to use the division -developed OEtM 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 OEtM 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 OEtM plan will be
incorporated as specific conditions in the source's Title V Operating Permit (if applicable). Additional monitoring
not listed in this OEtM 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: April 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:
Facility Name:
Bonanza Creek Energy
Operating Company, LLC
(BCEOC)
Facility
Location:
SWSW Sec 28, T5N, R62W
40.36444,-104.33594
State Antelope J-28 Production Facility AIRS ID (for existing facilities) 123 - 96AA
Facility (COGCC# 431937)
Is this facility located in the Denver
Metro and North Front Range 8 -hour
ozone nonattainment area?
Facility Equipment ID
Permit Number
® Yes
❑ No
Emission Units Covered by this OEtM form
CNDTK-01
13WE2810
AIRS Point ID
003
Page 1 of 4
CDPHE
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.
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.
►.t
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 wilt 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 j
Emissions Control
or
Recycling Method
Parameter
Monitoring Frequency
Ozone Nonattainment Area
Ozone Attainment Areas
❑ Permitted
Facility
Emissions
a 40 tpy VOC
Permitted
Facility
Emissions
t 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. `
Weekly b' c
Daily b' `
Weekly b' c
�1
Vapor Recovery
Unit (VRU) or
Recycled or
Closed Loop
System d
M
Monitoring requirements, including parameters and frequency, to be determined by the
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 XVII.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
M
H
Visual Inspection
Optical Sensor
_
❑
Auto -Igniter Signal
Thermocouple
Page 3 of 4
COLORADO
Air Pollution Control Division
Department of Public Health Er 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
OaM 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 shalt 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 OTtM 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
CDPHE
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Form APCD-307
APCD Internal Use Only
Received Date
Approved? ❑ Approval Date
Operating and Maintenance Plan Template for
Produced Water Storage Tanks
Ver. January 27, 2020
The Air Pollution Control Division developed this Operating and Maintenance Plan (O&M Plan) for produced water
storage tanks that use emissions controls, permitted at synthetic minor and major oil and gas facilities in the
State of Colorado. One O&M Plan may be used for multiple produced water storage tanks at one facility if each
are controlled and monitored in the same manner.
An OEtM 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 O&M Plan may
be modified without a permit modification or permit reissuance, but the operator must adhere to the
requirements of the existing approved O&M Plan until an approval letter is issued for the new O&M Plan.
The operator is required to use the division -developed O&M 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 OEtM 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 O&M 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: April 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: SWSW Sec 28, TSN, R62W
40.36444,-104.33594
Facility Name: State Antelope J-28 Production Facility AIRS ID (for existing facilities) 123 - 96AA
Facility (COGCC# 431937)
Is this facility located in the Denver
Metro and North Front Range 8 -hour
ozone nonattainment area?
® Yes
❑ No
Emission Units Covered by this OftM form
Facility Equipment ID
Permit Number
PWT-01
13WE2810
AIRS Point ID
004
Page 1 of 4
CDPHE
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Section 2 - Maintenance Schedules
Check one of the following:
El
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, shalt be made available to the division upon request.
Facility shall follow individually developed maintenance practices and schedules for the operation and
maintenance of the 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 O&M Plan to be considered complete:
Synthetic minor and major sources are required to maintain maintenance and monitoring records for the
requirements of this oam 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.
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.
►1
❑
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
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
Emissions Control
or
Recycling Method
Parameter
Monitoring Frequency
Ozone Nonattainment Area
Ozone Attainment Areas
❑ Permitted
Facility
Emissions
z 40 tpy VOC
❑ Permitted
Facility
Emissions
t 80 tpy VOC
❑ Permitted
Facility
Emissions
< 80 tpy VOC
/1 Permitted
Facility
Emissions
< 40 tpy VOC
Enclosed Flare
or Elevated
Open Flare'
Pilot Light / Auto -
igniter Monitoring
and
Visible Emissions
Observation
Daily b' `
Weekly b' c
Daily b' `
Weekly b, c
Vapor Recovery
Unit (VRU) or
Recycled or
Closed Loop
System °
M
Monitoring requirements, including parameters and frequency, to be determined by the
Other
M
Monitoring requirements, including specific parameters and frequency, to be described
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 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
❑
Visual Inspection
❑
_
Optical Sensor
❑
❑
Auto -Igniter Signal
❑
Thermocouple
Page 3 of 4
CDPHE
COLORADO
Air Pollution Control Division
Department of Public Health b 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
O&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.
a 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 O&M Activities
Please use this section to describe any additional notes or operation and maintenance activities, or if additional
space was required for 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 J-28
Production Facility (COGCC #431937). 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 APEN Requirements
Regulation 3, Part A, Section II: The produced water vaults, reboiler heaters, pneumatic devices,
fugitive equipment leaks, truck loading, and blowcase 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 produced water vaults, reboiler heaters, pneumatic
devices, fugitive equipment leaks, truck loading, and blowcase emissions are not subject to
permitting because they are not subject to APEN reporting [Regulation 3, Part B.II.D.1.a].
Condensate Truck Loading is not subject to permitting because the site is and exploration and
production facility that submerge fills less than 16,308 barrels of condensate per year [Regulation
3, Part B.II.D.1.1].
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 7, Part D Section I Oil and Gas Ozone Control Area Regulations
1
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 subject to these sections and are included on Bonanza Creeks
system wide control report.
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 exceed 2 tpy uncontrolled actual VOC emissions and are 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 required to install control
equipment per Section I.D and are thus subject inspection, recordkeeping and reporting
requirements of 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 VOC emissions, this facility is
required to perform leak inspections on a quarterly* 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
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
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applicability purposes. The total emissions from the storage tank exceed 2 tpy uncontrolled actual
VOC emissions and are 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 subject to control requirements under both I.D and II.C.1 and is therefore
subject to this section. Based on the uncontrolled VOC emissions, this facility is required to
perform STEM inspections on a quarterly basis.
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
not subject to this section because it loads out less than 5,000 barrels of hydrocarbon liquid per
year.
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 VOC emissions from the highest emitting tank, this facility is required to perform
AIMM inspections quarterly 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 subject to the gathering and control requirements of
Part D II.F because the wells onsite were constructed after 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
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
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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 onsite 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 (≤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.
Well Affected Facility: The 4 onsite wells, State Antelope 14-11-28HNB, State Antelope
E14-11-28HNB, State Antelope J-F-28HNB, and State Antelope J14-F11-28HNB, were
completed prior to September 18, 2015 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
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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.
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 but was modified
after September 18, 2015 when the newly reported wells were drilled. The fugitive
emission components are subject to this subpart.
Well Affected Facility: The 4 onsite wells, State Antelope 14-11-28HNB, State Antelope E14-
11-28HNB, State Antelope J-F-28HNB, and State Antelope J14-F11-28HNB, 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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