The URL can be used to link to this page

Browse Search

Home My WebLink About20203879.tiffCOLORADO Department of Public Health Et Environment Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 December 16, 2020 Dear Sir or Madam: RECEIVED DEC 21 2020 WELD COUNTY COMMISSIONERS On December 17, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for Bonanza Creek Energy Operating Company, LLC - North Platte K-22 Production Facility. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health a Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive 5., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Jared Potis, Governor I Jill Hunsaker Ryan, MPH, Executive Director Pub I -C Rey, ecJ oust/21 C G : P t-CTP), HI-(CS/TR0, Pc4(31.1 /ER lc Ilk OG (.70.") o I /oN /al �.0.2.0-3cS79 COPHE Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Bonanza Creek Energy Operating Company, LLC - North Platte K-22 Production Facility - Weld County Notice Period Begins: December 17, 2020 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Bonanza Creek Energy Operating Company, LLC Facility: North Platte K-22 Production Facility Well Production Facility NWNE Section 22 T5N R63W Weld County The proposed project or activity is as follows: The applicant proposes a reduction in throughput and emission limits for the condensate tanks, produced water tanks, hydrocarbon loadout, and low pressure gas flaring based on 2019 actual throughput. The applicant proposes revised VOC and HAP emission factors for the condensate tanks based on a July 2020 liquids analysis and ProMax run, and for the low pressure gas flaring based on a June 2020 gas analysis. Applicant also requests cancellation of the Vapor Recovery Tower at this facility. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • 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 14WE0494 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Joshua Jones Colorado Department of Public Health and Environment COLORADO Department of Public Health ft Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 2I 'COLORADO Department ot Public Health 6 Environment COLORADO Air Pollution Control Division Department of Public Heatth b Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 14WE0494 Issuance: 5 Date issued: Issued to: Bonanza Creek Energy Operating Company, LLC Facility Name: Plant AIRS ID: Physical Location: County: Description: North Platte K-22 Production Facility 123/9C07 NWNE Section 22 T5N R63W Weld County Well Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment Description Emissions Control Description CNDTI<-01 003 Sixteen (16) 800 barrel fixed roof storage vessels used to store condensate. Nine (9) enclosed combustors PWT-01 004 Two (2) 800 barrel fixed roof storage vessels used to store produced water. L-01 005 Truck loadout of condensate by submerged fill. P-01 011 One pneumatic pump used for water transfer. LPGFL 013 Venting of gas from thirteen (13) low pressure separators during vapor recovery unit (VRU) downtime. Four (4) dedicated enclosed combustors. Point 011: This pump may be replaced with another pump in accordance with the provisions of the Alternative Operating Scenario (AOS) in this permit. 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.) Page 1 of 17 1� COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado EMISSION LIMITATIONS AND RECORDS 2. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4. ) Annual Limits: Equipment ID AIRSPoint Tons VeOCYear CO Emission Type NO„ CNDTK-01 003 0.8 21.2 3.7 Point PWT-01 004 --- 0.4 --- Point L-01 005 --- 0.5 --- Point P-01 011 --- 2.1 --- Point LPGFL 013 0.4 10.1 1.8 Point Ote: See "Notes to Permit Hnlrlar" fnr infnrmatinn nn nmiceinn f'�,-r.,r� .. ate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month, a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 3. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 4. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment ID AIRS Point Control Device Pollutants Controlled Page 2 of 17 COLORADO Air Pollution Control Division Department cf Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado CNDTK-01 003 Nine (9) enclosed combustors VOC and HAP PWT-01 004 Nine (9) enclosed combustors VOC and HAP L-01 005 Nine (9) enclosed combustors VOC and HAP P-01 011 Nine (9) enclosed combustors VOC and HAP LPGFL 013 Four (4) dedicated enclosed combustors VOC and HAP PROCESS LIMITATIONS AND RECORDS 5. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4. ) Process Limits'' Equipment ID A{RS Point Process Parameter Annual Limit CNDTK-01 003 Condensate Throughput 83,950 barrels PWT-01 004 Produced Water Throughput 54,750 barrels L-01 005 Condensate Loaded 83,950 barrels P-01 011 Venting of motive gas 5.3 MMscf LPGFL 013 Gas vented from low pressure separators 2,50 MMscf Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month, a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 6. Point 013: The owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the low pressure separator(s) to the enclosed combustors using a flow meter. The flow meter must be calibrated and maintained per the manufacturer's specifications and schedule. The flow meter must continuously measure flow rate and record total volumetric flow vented from the separators. The meter shall be installed such that it measures only the volume from this emission point (Point 013) routed to the enclosed combustor(s). The owner or operator must use monthly throughput records to Page 3 of 17 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 7. Points 003, 004, 005, 011, and 013: 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. Points 003 and 004: The storage tanks covered by this permit are subject to Regulation Number 7, Part D, Section I. The operator must comply with all applicable requirements of Section I and, specifically, must: Comply with the recordkeeping, monitoring, reporting and emission control requirements for storage tanks; and Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Part D, Section I.C.) 10. Points 003, 004, 005, and 013: The combustion devices covered by this permit are subject to Regulation Number 7, Part D, Section Il.B.2. General Provisions (State only enforceable). If a combustion device is used to control emissions of volatile organic compounds and other hydrocarbons to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.24; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This combustion device must be equipped with an operational auto -igniter according to the schedule in Regulation Number 7, Part D, Section II. B.2.d. (State only enforceable) 11. Points 003 and 004: The storage tanks covered by this permit are subject to the emission control requirements in Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to March 1, 2020. The source must follow the inspection requirements of Regulation Number 7, Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. (State only enforceable) Page 4 of 17 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 12. Points 003 and 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. The owner/operator shall maintain records in accordance with Regulation No. 7, Part D, Section II.C.3. and make them available to the Division upon request. The owner or operator shall maintain records of STEM, including the plan, any updates, and the certification, for the life of the storage tank. The owner/operator will maintain records of all required inspections and monitoring for a period of two years. (State only enforceable) 13. Point 005 (L-01): Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by using (a) submerge fill and (b) a vapor collection and return system and/or air pollution control equipment. Compliance with Section II.C.5. must be achieved in accordance with the following schedule: (Regulation Number 7, Part D, Section II.C.5.a.) (State only enforceable) • Facilities constructed or modified on or after May 1, 2020, must be in compliance by commencement of operation. • Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021. • Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.5.a.(i)(B) that exceed the hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal to 5,000 barrels per year on a rolling 12 -month basis must control emissions from loadout upon exceeding the loadout threshold. 14. Point 005 (L-01): Storage tanks must operate without venting at all times during loadout. (Regulation Number 7, Part D, Section II.C.5.a.(ii)) (State only enforceable) 15. Point 005 (L-01): The owner or operator must, as applicable (Regulation Number 7, Part D, Section II.C.5.a.(iii)) (State only enforceable): • Install and operate the vapor collection and return equipment to collect vapors during the loadout of hydrocarbon liquids to tank compartments of outbound transport vehicles and to route the vapors to the storage tank or air pollution control equipment. • Include devices to prevent the release of vapor from vapor recovery hoses not in use. • Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to transport vehicles unless the vapor collection and return system is in use. • Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. • The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loadout. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring. Page 5 of 17 COLORADO Air Pollution Control Division Department of Put:4w Health £r Environment Dedicated to protecting and improving the health and environment of the people of Colorado 16. Point 005 (L-01): The owner or operator must perform the following observations and training (Regulation Number 7, Part D, Section II.C.5.a.(iv)) (State only enforceable): • The owner or operator must observe loadout to confirm that all storage tanks operate without venting when loadout operations are active. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring, • If observation of loadout is not feasible, the owner or operator must document the annual loadout frequency and the reason why observation is not feasible and inspect the facility within 24 hours after loadout to confirm that all storage tank thief hatches (or other access point to the tank) are closed and latched. • The owner or operator must install signage at or near the loadout control system that indicates which loadout control method(s) is used and the appropriate and necessary operating procedures for that system. • The owner or operator must develop and implement an annual training program for employees and/or third parties conducting loadout activities subject to Section II.C.5. that includes, at a minimum, operating procedures for each type of loadout control system. 17. Point 005 (L-01): The owner or operator must retain the records required by Regulation Number 7, Part D, Section II.C.5.a.(v) for at least two (2) years and make such records available to the Division upon request. (State only enforceable) • Records of the annual facility hydrocarbon liquids loadout to transport vehicles throughput. • Inspections, including a description of any problems found and their resolution, required under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log. • Records of the infeasibility of observation of loadout. • Records of the frequency of loadout. • Records of the annual training program, including the date and names of persons trained. 18. Point 005 (L-01): Air pollution control equipment used to comply with this Section II.C.5. must comply with Section II.B., be inspected in accordance with Sections II.C.1.d.(ii) through (v), and achieve a hydrocarbon control efficiency of 95%. (Regulation Number 7, Part D, Section II.C.5.a.(vi)) (State only enforceable) 19. Point 013 (LPGFL): The separators covered by this permit are subject to Regulation 7, Part D, Section II.F. On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the commencement of operation by air pollution control equipment that achieves an average hydrocarbon control Page 6 of 17 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. 20. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division -approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) (State only enforceable) OPERATING Et MAINTENANCE REQUIREMENTS 21. Points 003, 004, 005, 011, and 013: Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (0&tM) 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 OftM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Periodic Testing Requirements 22. Point 003: On an annual basis, the owner or operator must complete a site specific analysis ("Analysis"), including a compositional analysis of the pre -flash pressurized hydrocarbon liquid routed to the equipment covered in this permit. Testing must be in accordance with the guidance contained in PS Memo 05-01. Results of the Analysis must be used to demonstrate that the emissions factor established through the Analysis is greater than or equal to the emissions factor submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. 23. Point 013: On an annual basis, the owner/operator shall complete a site specific extended gas analysis ("Analysis") of the natural gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be used to demonstrate that the emissions factor established through the Analysis are less than or equal to, the emission factor submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factor submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit Page 7 of 17 COLORADO Air Pollution Control Division Department of Publtc Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). ALTERNATE OPERATING SCENARIOS 24. Point 011: This pump may be replaced with a like -kind pump in accordance with the requirements of Regulation 3, Part A, Section IV.A and without applying for a revision to this permit or obtaining a new construction permit. A like -kind replacement pump must be the same make, model and capacity as authorized in this permit. 25. Point 011: The owner or operator must maintain a log on -site or at a local field office to contemporaneously record the start and stop dates of any pump replacement, the manufacturer, model number, serial number and capacity of the replacement pump. 26. Point 011: All pump replacements installed and operated per the alternate operating scenarios authorized by this permit must comply with all terms and conditions of this construction permit. ADDITIONAL REQUIREMENTS 27. All previous versions of this permit are cancelled upon issuance of this permit. 28. A revised Air Pollutant Emission Notice (APEN) must 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 NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Page 8 of 17 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 29. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Equipment ID AIRS Point Equipment Description Pollutant Emissions - tons per year Threshold Current Permit Limit CNDTK-01 003 Condensate Storage Vessels NOx VOC 50 50 1.2 34.3 PWT-01" 004 Produced Water Storage Vessels L-01 005 Hydrocarbon Loadout P-01 011 Pneumatic Pump LPGFL 013 Separator Venting _ Insignificant Sources Note: APEN and permit exempt sources do not have permit limits. However, the PTE of these sources (excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR. GENERAL TERMS AND CONDITIONS 30. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. Page 9 of 17 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 31. If this permit specifically states that final authorization has been granted then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 32. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 33. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 34. Each and every condition of this permit is a material part hereof and is not severable Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 35. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 36. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Page 10 of 17 COLORADO Air PoUution Control Division Department cf Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Joshua Jones Permit Engineer Permit History Issuance Date Description Issuance 1 September 2, 2014 Issued to Bonanza Creek Energy Operating Company, LLC Issuance 2 March 27, 2017 Cancel point 006, 009, 010, and 012. Add point 014. Adjust emission factors and emissions for all other points. Update to permit language. Issuance 3 April 25, 2019 Issued to Bonanza Creek Energy Operating Company, LLC Modification to Point 003,`004, 005, 013 and addition of Point 023. Reflecting addition of new wells and increased throughputs and emissions limits. Removal of cancelled points 014 and 009. Issuance 4 March 24, 2020 Issued to Bonanza Creek Energy Operating' Company, LLC Modification to revise emission factors and process limits based on updated data and initial testing requirements for Issuance 3. Decrease condensate throughput and emission limits for Point 003 and 005. Revise emission factors and increase emission limits for Point 013 and 023. This Issuance Issued to Bonanza Creek Energy Operating Company, LLC Modification to reduce annual throughput and emission limits and revise emission factors based on updated liquids analysis for condensate tank (point 003). Modification to reduce annual throughput and emission limits for produced water tanks (point 004). Modification to reduce annual throughput and emission limits for condensate loadout (point 005). Modification to reduce annual throughput and emission limits and revise emission factors based on updated gas analysis for low pressure separator venting (point 013). Cancellation of Point 023 for Vapor Recovery Page 11 of 17 COLORADO Air Pollution Control Division Department of Public Health b Env ronment Dedicated to protecting and improving the health and environment of the people of Colorado ITower venting. Page 12 of 17 COLORADO Air Pollution Control Division Department of Public Health Fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/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 sources operates at the permitted limitations. Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr)` CNDTK-01 003 Benzene 71432 3,868 193 Toluene 108883 3,435 172 Ethylbenzene 100414 210 11 Xylenes 1330207 1,103 55 n -Hexane 110543 30,407 1,520 2,2,4- Trimethylpentane 540841 664 33 PWT-01 004 Benzene 71432 383 19 n -Hexane 110543 1,205 60 L-01 005 Benzene 71432 34 2 n -Hexane 110543 302 15 P-01 011 Benzene 71432 137 7 Toluene 108883 154 8 Ethylbenzene 100414 29 1 Xylene 1330207 82 4 n -Hexane 110543 1,128 56 224 TMP 540841 91 4 LPGFL 013 Benzene 71432 2,852 143 Page 13 of 17 ato COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Toluene Ethylbenzene Xylenes 108883 685 34 100414 9 0 n -Hexane 2,2,4- Trimethylpentane _ Note: All non -criteria reportable pollutants in the tab a above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 1330207 24 1 110543 25,677 540841 5 1,284 0 5) The emission levels contained in this permit are based on the following emission factors: Point 003 (CNDTK-01): Storage Tank Waste Gas CAS # Pollutant NOx Uncontrolled Emission Factors lb/bbl 0.0159 Controlled Emission Factors lb/bbl 71432 108883 100414 1330207 110543 540841 CO VOC' 0.0724 0.0159 0.0724 0.5045 0.0023 Source AP -42 Chapter 13.5 Benzene Toluene 10.09 0.046 Ethylbenzene Xylene n -Hexane 0.041 0.0021 0.0001 0.0025 0.0131 0.0007 0.0181 2,2,4- Trimethylpentane 0.362 0.0079 0.0004 ProMax ProMax ProMax ProMax ProMax ProMax ProMax Note: The controlled emissions factors for this point are based on a combustor control efficiency of 95%. Emission factors for NOx and CO were converted from lb/MMBtu to lb/bbl based on a waste gas heat content of 3,040 Btu/scf and a GOR of 76.88 scf/bbl as derived from ProMax. Pilot Light Combustion CAS # Pollutant NOx Uncontrolled Emission Factors lb/MMscf 206.69 Controlled Emission Factors lb/bMMscf CO 206.69 Note: NOx and CO emissions from pilot light combustion have been calculated942.25 based on a pilot gas flow rate of 18.3 scf/hr per combustor, with nine (9) combustors controlling these tanks, for a total of 1.4 MMscf/yr. Emission factors were converted from lb/MMBtu to lb/MMscf using a HHV of 3,040 Btu/scf. Point 004 (PWT-01): Source CAS # Pollutant VOC 942.25 Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl AP -42 Chapter 13.5 Source 0.262 0.013 CDPHE Page 14 of 17 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source 71432 Benzene 0.007 0.0004 CDPHE 110543 n -Hexane 0.022 0.001 CDPHE Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Point 005 (L-01): Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source V0C 0.236 0.012 CDPHE Benzene 71432 0.00041 2.1e-5 CDPHE n -Hexane 110543 0.0036 1.8e-4 CDPHE Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Point 011 (P-01): CAS # Pollutant Wt% Emission Factors = Uncontrolled lb/MM scf vented Emission Factors - Controlled lb/MM scf vented Source V0C 26.38 16,056.3 802.82 All emission factors are based on the displacement equation and wet gas analysis. 71432 Benzene 0.042 25.7 1.29 108883 Toluene 0.047 28.9 1.45 100414 Ethylbenzene 0.009 5.4 0.27 1330207 Xylenes 0.025 15.0 0.75 110543 n -Hexane 0.350 212.8 10.64 540841 224 TMP 0.028 7.7 0.39 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. The displacement equation can found in "EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)." Point 013 (LPGFL): Low Pressure Separator Vent Gas CAS # Pollutant Uncontrolled Emission Factors (lb/MMscf) Controlled Emission Factors (lb/MMscf) Source N0x --- 247.18 AP -42 Chapter 13.5 CO --- 1,126.85 V0C 160,921.91 8046.10 Site -Specific Page 15 of 17 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CAS # Pollutant Uncontrolled Emission Factors (lb/MMscf) Controlled Emission Factors (lb/M/VGcf) Source Gas Analysis (sample date 6/10/2020) 71432 Benzene 1,140.72 57.04 108883 Toluene 273.84 13.69 100414 Ethylbenzene 3.50 0.18 1330207 Xylene 9.51 0.48 110543 n -Hexane 10,270.64 513.53 540841 TL_ __-a-_11_ 2'2'4- Tnmethylpentane A _. _•___•. _ 2.0 • 0.1 rs for this point are based on a control efficiency of 95%. Pilot Light Combustion CAS # Pollutant Uncontrolled Emission Factors lb/MMscf Controlled Emission Factors lb/bMMscf Source NOx 247.18 247.18 AP -42 Chapter 13.5 1.1�..�. CO 1,126.85 1,126.85 . NOx and CO emtsslons from pilot light combustion have been calculated based on a pilot gas flow rate of 18.3 scf/hr per combustor, with four (4) combustors contro ling these separators, for a total of 0.64 MMscf/yr. Emission factors were converted from lb/MMBtu to lb/MMscf using a HHV of 3,635 Btu/scf. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date, call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAP PSD True Minor Source of: CO, NOx, VOC NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.Qov/ Page 16 of 17 avze, COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado rart 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: Categories National Emission Standards for Hazardous Air Pollutants for Source MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 17 of 17 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Package #: Received Date: Review Start Date: Joshua loves 4:34124 - 5/3/2020. 11;12/2020 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: Explor 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 €-: Ezk'cnergy Gperating Company, LLC 123 9C07 North Platte K-22 Production. Facility Weld County N, Range 63W Production Well Pad 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 age Tank CNDTK-01 Yes 14WE043 5' No Permit Modification 004 Storage Tank PWT-01 Yes 14WE04`}4 5 No Permit Modification 005 Liquid Loading L-01 Yes 14WEC•=494 S No Permit Modification 013 - Separator Venting LPGFL Yes 14W'E0494 5 No: Permit Modification 023 Separator Venting VRT-01 Yes 14WE0494- 5 No Cancellation Quadrant Section Township Range NWNE 22 5N Section 03 - Description of Project Requesting lower throughput and emission limits for condensate tanks (CNDTK-01, point 003), based on actual condensate throughput for 2019; and new emission factors based on an updated natural gas liquids analysis (July 2020) and ProMax model run. Requesting lower throughput and emission limits for produced water tanks (P+tJT-01, point 004) based on actual2019 throughput. Requesting lower throughput and emission Emits for condensate truck tcadout (L-01, point 005) based on actual 2019 throughput. Requesting lower throughput and emission limits for IOW pressure gas flaring (LPGFL, point 01:3) based on 2019 actual throughput and updated emission factors developed from a Lune 2020 gas analysis. Cancellation request for the vapor recovery tower (VRT-01, point 023). Notification that compressor engine E-11 (point 024, permitted under G -P02) is no longer in service and that a cancellation notice will be submitted when the unit is removed from the site. Sections 04, OS & 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 Requirement Was a quantitative modeling analysis required? N•o 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 true minor? Is this stationary source synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) N Yes SO2 NOx CO VOC PM2.5 PM10 TSP HAPs n n n n n n Colorado Air Permitting Project Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) ® �.I C ❑ © O PM10 TSP HAPs O El Tank(s) Erni55 s?`a Inventory Section 01 -Administrative Information 'Facility Al Rs ID: County Plant Poin 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= Requested Permit Limit Throughput= Barrels (bhl) per year Potential to Emit (PTE) Condensate Throughput = Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted perBBL of liquids produced = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 47954.2 Barrels (bbl) per year Requested Monthly Throughput= Barrels (bbl) per year Btu/scf = scf/bbl Potential to Emit (PTE) heat content of waste gas routed to combustion device = Control Device 1S326.4. MMBTU per year 1941-.,.8 MMBTU per year =r.3 MMBTU per year Section 04 -Emissions Factors &IVIethodologies Will this storage tank emit flash emissions? Emission Factor. Condensate Tank Pollutant Uncontrolled Controlled Vh/bbl) (lb/bbl) (Condensate Throughput) (Condensate Throughput) Emission Factor Source VOC Toluene 224TMP Pollutant PM10 PM2.5 SO NOx CO Pollutant Pilot Light Em ssion Uncontrolled (Ib/MMscf) Emission Factor Source (Pilot Gas Throughpu Uncontrolled (Ib/MMBtu) (Pilot Gas Hea Combusted) Emission Factor Source Section 05 - Emissions Inventorlp 9 ECDs at 18.3 scf/hr per pilot 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) PM30 PM2.5 SOx NOx VOC CO 0.1 ft.0S94 0,3844 0.7294 04824 15.2 0.1 0.0894 nnggd 3.[5.4 0,0834 15.2 0,0 9.0 0,O ..y ..._ .2 0.8 a'::8 0,8 ._ ,,. _38.4 423.4 Ya3S 11.2 423.5 241.9 33947.1 ?-7 3,7 3.7 5331.E Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/Year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene 32�6�y1.7 385°.7 143.1 3551.7 193.1 4410 .3442.0 MA 3442^. _—_.1 _..v... 2099 10.5 27.4.9 10.5 7140.0 Barrels (bbl) per month 3 of 19 CAUsers\jojones\Desktop \ MINE \TV\Oil & Gas \Syn Minor CPs for Serious \North Platte K-22\14WE0494,CP5_PA Storage Tani ," m3ssjc ns inventory xylene n -Hexane 224 TMP W99.; 1095.; 55.0 663._2 30385.9 9553.2 1515.5 33.2 663_2 1529.6 335.2 4 of 19 C:\Users \jojones\ Desktop \ MINE \TV\Oil & Gas \Syn Minor CPs for Serious \North Platte K-22\14WE0494.CP5 PA Storage Tank(s) Emus ons Inventory / 5ection 06- Regu Iory Summan Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Part Ddection IC, D, E, F Storage tank .s subject _ - "art D, Section I C -F - Regulation 7, Part D,Section I.G, C Storage ana is _.. ' - oettion I.G . Regulation 7, Part Ddection II.6, C1, C.3 Storage tank is subject or _. D, Section II, B, C.1$, C.3 Regulation 7, Part D,Section II.C.2 Storage tank is subject to RemDeticio '. Port D. Section iI.C.2 Regulation 7, Part D,Section ll.C.4a.(i) Storage Tank is not subject to Rego . 7, Part D, 5ecticm II.C 4,1(i) Regulation 7, Part D,Section II.C.4a,(ii) to s not subject to Regulation 7, Dart 0, Section ilC 7 77. . Regulation 6, Part A, NSPS Subpart Kb x. g - Tank is not subject to MPS _ b- Regulation 6, Part A, NSPS Subpart 0000 btorege. Talks not subject to NSPS OCH30 NSPS Subpart 0000a _to -_ _ enl; is not subject to Hi-IPS! 00Oa. Regulation 8, Part E, MALT Subpart HH �torag-='anx s not subject to 14ACf HH (See regulatory a pplicabilityworksheet 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 to7'a"' estimate emissions? If yes, are the uncontrolled actuator 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 zmissions for a condensate storage tank estimated to be greater than or equal to 80 tpy? fives, the permit will contain an Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company use a site spedfic emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted (for produced water tanks, a pressurize liquid sample must be analyzed using flash liberation analysis)? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility hasaot been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03 Does the company request a control device efficiency greater than 95% for a flare or combustion device? 1f yes, the permit will contain intial and periodic compliance testing in accordance with PS Memo 20-02 Section 08 - Technical Analysis Notes ProMak results for VOC-andHAP based on low pressure liquids analysis and flow rate from single well (A-E-22HC) sampled on. July 16, 2020. VOC emissions from the. pilot lights are included here but were not provided by the applicant. These calculate to 23.71b/yr. No request was made to applicant to revise calculations to include these emissions since it did not change the requested permit limit. Section 09 - SCC Coding and Emissions Factors (For Inventory Use Onivj AIRS Point d 103 Process it 01 5CC Code Uncontrolled Emissions Pollutant Factor Control% Units PM10 PHD CI lb/1,000 gallons Condensate throughput PM2.5 0.35 D Ib/1,000. gallons Condensate throughput 50x +i._0 0 lb/1,000 gallons Condensate throughput NOx 0.45 0 lb/1,000 gallons Condensate throughput. VOC 240.24 95 lb/1,000 gallons Condensate throughput CO 2.11 0 lb/1,000 gallons Condensate throughput Benzene _10 95 lb/1,000 gallons Condensate throughput Toluene C.3_ 16/1,000 gallons Condensate throughput Ethylbenzene 1-05 95 lb/1,000 gallons Condensate throughput Xylene 0:31 95 lb/1,000 gallons Condensate throughput n -Hexane .°.62 95 lb/1,000 gallons. Condensate throughput 224 TMP 0.19 95 lb/1,000 gallons Condensate throughput 5 of 19 CAUsers\jojones\Desktop \ MINE \TV\Oil & Gas \Syn Minor CPs for Serious \North Platte K-22 \14WE0494.CP5_PA Storage Tank Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado • e, ulitlon 3 • : resA and B-APEN and P_ge. ufgments ATTAINMENT Smirce f "___.3 M tAre.; 1. Are uncontrolled actual emissions from any criteria pollutants from this ind NIdual source greater than 2 TPY (Regulation 3, Part A, Section ll.0.1.a17 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicabilky)7 3. Aretotal fad' uncontrolled VOC emissionseater than 5TPY, NOx greaterthan 10 TPY or CO emissions: renter than 10 TPY Re: ulatian 3. Part e, Section II. D. 3)7 NON -ATTAINMENT 1, Are uncontrolled efnissions from any criteria pollutants from this individual source greater than 1TPY (Regulation 3, Part A,Section ll.D.l.a)7 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on 3. Are total facility uncontrolled VOC emissions : realer than 2 TPY, NOx greater than 5TPY or CO emissions greaterthan 10 TPY Re:ultion 3, Part B, Section ll.D.2)7 grandfather applicablli[y)1 Source Colorado Rego fl7 pit: v2c,a k a .. w on Color D se 1. Is this storage tank located in the 8 -hr ozone control area or an ozone tr attainment/maintenance area (Regulation 7, Part D, Section I.A.1)7 2. Isthis storage tank located at oil and gas operations that collect, storeor handle hydrocarbon carbonliquids orproduc d water AND that are located t or upstream of a ri.ural gas 3. Is this storage tank located at a natural gas processing plant (Regulation 7, Part D, Section I.G)7 4'. Does this storage tank contain condensate? processing plant (Regulation 7, Part D, Section l.A.117 5. Does the storage tank exhibit "Flash"(e.g. storing non -stabilized liquids) emissions (Regulatlon 7, part D, Section 1.6,2)7 6. Are uncontrolled actual emissions&th tora e tank e•u l to or greater than 2 tons per year VOC Rlation 7, Part D, Section 1. D. 3.a(il))7 Mrane to 5,,,dafton 7. Part lb, Section PartD, 3ecBen I.C.1 —General Requirements for Air Pollution Comrol Equipment —Prevention of Leakage Part D, Section I.C.2—Eruksion Estimation Procedures Part D, Section I.D—Embsions Control Requirements Part D, Section 1.E 7 -Monitoring Part 0, Section I.F-Recordkeeping and Reporting Part D, Section l.G.2- Emissions Control Requirements Part 0, section I.C.1.a and b —General Requirements for Air Pollution Control Eq uipment of Leakage Colorado qe elation 7 Part 0 Sect:__ II 1. Is this storage tank lotted at a transmission/storage facility? 2. Is the storage tank' located at an oil and gas exploration and production operation , well production fecilityz, natural gas compressorstation'ar natural 3. Does this storage tank have a freed roof (Regulation 7, Part D, Section ll.A20)? 4. Are uncontrolled actual emissions of the sgas processing plan[°(Regulation ], Part D, Section ll.C)? tora:e tanke 'g•tark - -_ equal to or greater than 2tns .er ear VOC lat on ], Part D, Section ll.C.l.c7 Part D, Section 11.8 — GI Provisions far Air P Ilbtion Control Equipment and Prevention of Emissions Part DSection IIC.1- Emissions Control and Monitoring Provisions Part D, Section II.C.3 - Recordkeeping Requirements • 5. Does the storac tank contain only "stabilized"liquids(Regulation 7, part 0, Section ll.C.2.6 Part IS, Section II.C.2- Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment is the controlled storage tanklocated at a wellproduction facility, naturalgas compressor station, or naturals. processing plant constructed on or after M 6. thta additional controlled g I t rted to receive an anticipated se'n[hrouh•mof hydrocarbon liquids or •raducd water (R May 1, 2020 or loca[edazafacil,ry that was modified on or after May 1, 2020, such D. Section II.C 4 a (q7 Is the II dtank- - titan 7, Part storagel t dat awell production facility, naturalg p station or natural 7. 2021, h h additional controlled storage vessel is e acts processing plantbonz[quids oon r pro used w.ery; 2021 ,..c anticipated lncreasemthroughput of hydrocarbon liquids or produced wter(Regulat 40 CFR Part 6o Sub art Kbstandards of Perfarma x 1. Is the individual story equal to7 anti Li restore eves Is storage vessel capacity Greater than ore Ito ]5 cubic meters 2. Does the storage vessel meet the following qua (^'11'472 BBLs)(gO CFR E0.1106(a)J? a. Does the vessel has odes n exemptlon in 6o 1116(d)(4)7 3. Wasthis story IH capacity less than or equal to 1,589.874 ma[ -10;000 BBL] used for petroleum' or condensate stored processed, or treated prior m custody transfer' as defined in 60.111h? storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23,1984 (40 CFR 60.S10b(a))? 4. Does the tank meet the definition of "storage vessel"' in 60.111b? 5. Does the storage vessel store a"volatile organic liquid(VOLI'as defined in 60.111b7 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 psil and without emissions to the atmosphere (60.11ob(d)(2))T or b. The design capacity is greater than or equal to 151 m [-950 BBL] and stares a liquid with a maximum true vapor pressure` less than 3.5 kna (60.1106(6))7; or c. The design capacity is greater than or equal to 75 M [-472 BBL) but less than 151ro(-950 BBL] and stores a liquid with a maximum true vapor 7. Does the storage tank meet either of the following exemptions from control requirements:par pressure` less than SS OkPa(601106(b))? a. The design capacity greater tha b The d equal 151 m'[-950 BBL] and stores a liquid with a maximum true vapor pressure greeter than or equal to 35 kna but less than 5.2 kPa7;or capacitygreater tha equal to 75 M'(-471 BBL) but less than 151 m'('950 BBL] and stores a liquid with a maximum true vapor pr.sure greater than q [ 150k h -y -��^27.6 kpa7 or located at a facility that was modified on or after January on 7, Part D, Section II C4 a.(il7 4o CFR Par,eg Sub rat 00000000a standards of PeAa a eforCrude oil and Natural Gas productlon Transmission and pistribution 1. Is this storage vessel located[ a facility in the onshore ail and ntu 2. Was this store ragas pros40Csegment, tween Augustgas 23, 2011andSeatembg segrnent or er18,gas 20 transmission and storage storage vessel constructed, modified(seedefinitions 40 CFR,60.2)betweenember 23, 2011and5eptember 18, 20357 g segment of the Industry? 3, Was this storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after September 18, 20157 4. Are. potential VOC emissions from the individual storage vessel greater than or equal to 6 tons per year? 5. Does thls storage vessel meet the definition of"storage vessel"' per 60.5430/60.5430a? 6. Is the storage vessel sub err to and controlled in accordance with re • ulremeMs for story: a vessels in 40 CFR Part 60 Sub •art Kb or 40 CFR Part 63 Sub • art HH? [Note: fie storage vessel Is previously determined to be subject. NSPS 0000/0000a due to emissions above 6 tans per year VOC tin the applicability determination date, it should remain subject to NSPS 0000/0000a 60.5365(e)(2)/60.5365a(e)(2) even if potential VOC emissions drop below 6 cans per year) per 40 CFR Part 63 Sub art MACT HH Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets ekher of the fallowing criteria: a. A facility that processes, upgrades or stares hydrocarbon liquids' (63.760(a)(2)); OR b. A facility that processes, upgrades ar stores natural gas priortothe point at which natural gas enters the naturalgastransmizsion and storage source ctoge 2. Is the tank located at a facility that a major'for HAPs7 ryoredeliveredivafinal end user= (63.760(a)(31)7 3. Does thetank meet the definition of "storage vessel"' in 63.)617 4. Does the tank meet the definition of"storage vessel with the potential for flash emissions"'per 63.7617 S. is the tank subject to control requirements under 40 CFR Part 60, Subpart Kh or Subpart 00007 Subpart A, General provisions per §63.]64 (a) Tabl §63.766 - Emissions Control Standards §63.773. Monitoring §63.774-Recordkeepleg §63.7]5 -Reporting RAC= Review RACT review Is required If Regulation 7 does net apply AND If the tank Is in the ran -attainment area. If the tank meets both criteria, then review RACT requirements Disclaimer Source Requires an APEN. Go to Go to next question Source Requires a permit ource Requires an APEN. Go to Go to next question Source Requires a permit continue -You have Indicated th Continue - You have indicated th forage Tank b not subject to Re Continue You have indicated th Go to the nert question -You ha Go to the nextquestion o. rce s subject to parts of Reg .r"a Source is subject to all provision t rage Tank is not subjert to Re E] ]G t e next qtion Sm ragethTani snueso[su6JeR NS PS °nth,. -You have Indicated th Go to the question 4. forage Tank Is not subject NSPS Storage Tank Is not subject NSPS Continue - You have indicated th Storage Tank Is not subject MAC This document assists operators with determining applicability of certain requirements of the Clean Air Act, ifs 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 cvcumstances. This document does not change or substitute for any law, regulation, many 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 Aif Quality Control Comm/ssi n regulations, the language of the statute or regulation will control. The use of non -mandatory language such as'recommend,"7ney,"`should,"and °can,"is intended to describe APCQ interpretations and recommendations. Mandatary terminology such as "must" and `required" are intended to describe controlling requirements under the terms of the Clean Air Act and Au Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Storage Tank(s) Emissions inventory Section 01 -Administrative Information Facility AIRS 10: 123 County 9007 Plant 004 Point Section 02 - Equipment Description Details Storage Tank Liquid Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Two (2) 806 Limited Process Parameter Emissions area roof storage vessels used me (9) enclosed Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions -Storage Tank(s) Actual Throughput = (Requested Permit Umit 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 = oduced water. 3). 54,750.0 Barrels(hbl) per year 54,750.0 Barrels (bbl) per year 54,750.0≥. Barrels (bbl) per year 1496.0 Btu/scf 38.0 scf/bbl Potential to Emit (PTE) heat content of waste gas routed to combustion device = Control Device Requested Monthly Throughput= 2,948.5 MMBTU per year 2,945.5 MM BTU per year 2,943.6 MMBTU per year Pilot Fuel Use Rate: Pilot Fuel Gas Heating Value: 0 scfh 0 Btu/scf n.0 MMscf/yr 6i.a MMBTU/yr Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Pollutant VOC Benzene Section 05 - Emissions Inventory Toluene Ethylbenzene Xylene n -Hexane 224 TMP Pollutant PM10 PM2.5 Pollutant PM10 PM2.5 sox VOC CO Produced Water Tank Uncontrolled Controlled (lb/bbl) (Produced Water Throughput) 0.2620 0.0070 (Ib/bbl) (Produced Water Throughput) 0.0000 0.0000 0.0220. 0.0011 --.1.0000 Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (1b/bbl) [waste heat (Produced Water combusted) Throughput) 0.0075:. 0.6,004 0.0075 0.0004 0.0000 Pilot Light Emissions Uncontrolled (Ib/MMBtu) (Pilot Gas Heat Combusted) Uncontrolled (Ib/MMscf) (Pilot Gas Throughput) 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Emission Factor Source Emission Factor Source Emission Factor Source 4650.0 Barrels (bbl) per month Pilot fuel use is accounted for with condensate tank calculations 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 NO8 VOC CO 0.0 0.0 CO 0.0 '.,. 1,9 4.0 0.0 �.r .. 0-0 - -.. 1.4 �.0 0.0 0.0 0.0 0.1 0.1 a._ 0.1 _._ 17.0 7.2 7.2 0.4 7.2 0.4 60.9 0.5 0.5 0.5 0.5 s. 77.6 Hazardous Air Pollutants Potential to Emit Uncontrolled Nits/year) Actual Emissions- Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene 3833.3 383.3 1_.2 '0.0 383.3 19.2 0.0 0,0 0.0 00 0.0 0.0 0.0 0.0 e.o 8 of 19 CAUsers\jojones\Desktop \ MINE \TV\Oil & Gas \Syn Minor CPs for Serious \North Platte K-22\14WE0494.CP5 PA Storage Tanks Emission_ Inventory zylene n -Hexane 2247MP 0.0 0.0 0.0 0.0 60.2 1204.5 1204.5 1204.5 0.0 0.0 0.0 0.0 9 of 19 CAUsers\jojones\ Desktop \MINE\N\Oil Pr Gas \Syn Minor CPs for Serious \North Platte K-22\14WE0494.CP5_PA Storage Tank(s) Emissions Inventory Section 06 - Regulatory Sum Regulation 3; Parts A; B Regulation 7, Part 0;Section I.C, D, E, F lai n t 7 Part Ei, S..ctlon I.C-F Regulation 7 Part D,Section I.G, C k C Regulation 7 Part D,Section MB, C.1, C.3 , . , .. 7on 5 ct:c ;f, R, C.1 & C Regulation 7, Part D,Section II.C,2 =-; ,u'5, _ n 7 Part ti, Section II.C.2 2 Regulation 7, Part D,Section II,C.4.a.(i) r'r s t bles. C Motion 7 Part D, Section ..C,4.aii) Regulation 7, Part D,Section II.C.4.a.(ii) not subject tr.,- Regulation 7_ ?art 0, Section II.C.4.a(iil, b- f Regulation 6, Part -A, NSPS Subpart Kb _i,. nt subleot t MPS Kb Regulation 6, Part A; NSPS Subpart 0000 .. ,_ Tarn is not subject to fitiSPS GOOO NSPS Subpart 0000a Storage tank is not subject to 215PS OO00a, Regulation B, Part E, MACF Subpart HH Produce,' Wate.r Storage tank Is not subject rs MAU HH (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 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 she 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. 3 �u If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor hosed on guidelines in PS Memo 14-03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 08 - Technical Analysis Notes Combustion emissions from pilot lights are accounted for in the emissions for the condensate tank, since these share common control devices. NOX and CO emission limits were not included in the permit since they are below APEN reporting thresholds for this source. Section 09 -SCC Coding. and Emissions Factors (For Inventory Use Only). AIRS Paint # Process # 01 SCC Code Uncontrolled Emissions Pollutant Factor Control% Units PM10 0.91 0 lb/1,000 gallons Produced Waterthroughput PM2.5 0,011 _ lb/1,000 gallons Produced Water throughput SOx §REST _ lb/1,000 gallons Produced Water throughput NOx s.^_9 E lb/1,000 gallons Produced Water throughput VOC -6.24 95 lb/1,000 gallons Produced Water throughput CO 0.4 > lb/1,000 gallons Produced Waterthroughput Benzene 9.17 - 95 lb/1,000 gallons Produced Water throughput Toluene 0.00 95 lb/1,000 gallons Produced Water throughput Ethylbenzene 0.00 95 lb/1,000 gallons Produced Waterthroughput Xylene 0.0,5 _ 95 lb/1,000 gallons Produced Water throughput n -Hexane 0-52 .,_ lb/1,000 gallons Produced Water throughput 224 TMP 0,00 95 lb/1,000 gallons Produced Water throughput 10 of 19 CAUsers\jojones\Desktop \ MINE \TV\Oil & Gas \Syn Minor CPs for Serious \North Platte K-22\14WE0494.CP5 PA Storage Tank Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Para A and B -APE. and Permit Reouirements 1=a _c_Non Attain-nont Arco ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greaterthan 2 TPY (Regulation 3, Part A, Section 2. Produced Water Tanks have no grandfathering provisions 3. Are total facility uncontrolled VOC emissions greaten than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)? Yon 1-...e,r,.nc.._..d Chet source lain Mtn NAmrAirtn- omen Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutanisframthis individual source greaterthan 1TPY(Regulatian 3, Part A,Section ll.D.1.a)? 2. Produced Water Tanks have no grandfather..a provisions 3. Are total facility uncontrolled VOC emissions greater than 2TPY, NOx greater than 5 TPY or CO emissions greater than SO TPY (Regulation 3, Part B, Section ll.D.2)? Sour._ rem.. s nern. Colorado Regulation 7. Part 0, Section I.C-F & G 1. Is this storage tank located lit the 8 -hr ozone control area or any ozone nonattalnment area or attainment/maintenance area (Regulation 7, Part 0, Section I.A.1)? 2. Is this storage tank located at ail and gas operations that collect, store, or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processing plant (Regulation 7, Part D, Section I.A.1)? 3. Is this storage tank located at a natural gas processing plant (Regulation], Part D, Section I.G)? 9. floes thb storage tank contain condensate? 5. Does this storage tank exhibit "Flash" (e.g. storing non-stahilized emissions (Regulation 7, part D, Section l.G.2)7 6 Are uncontrolled actual emss'onsof this storage tank equal to or greater than 2 tons per year VOC (Regulation 7, Part 0, Section 403...)? !Source Requires an APEN. Go to Go. next question Source Requires a permit Source Requires an APEN. Go to Source Requires a permit Continue - You have indicated th Continue -You have Indicated th Storage Tank is not subject to Re Part D, SeNon I.Gl —General Requirements for Air Pollution Control Equipment — Prevention of Leakage Part O, Section 1.C.2— Emission Estimation Procedures t Part 0, Section I.D—Em5slons Control Requirements Part 0, Section I.E—Monitoring Part D, Section I.F—Recordkeeping and Reporting Snorn...Tauk ixnet subivnt action 1.6 Part 0, Section I.G.1- 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 transmgsion/storage facility? 2. Is this staragetanle located at an oil and gas exploration and production operation, well production facility', natural gas compressor stations or natural gas processing plane (Regulation 7, Part D, Section ll.C)? 3. Does the storagetank have afxed roof (Regulation 7, Part D, Section lLA.20)? 4. Are uncontrolled actual ermssons of this storage tank equal to or greater than 2 tons per year VOC (Regulation 7, Part 0, Section ll.CLrd? y Part 0, Section II.B—General Provisions for Alr 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 ll.C2.b)7 Store,Iuoie finmiAtIon . 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 nt a facility that was modified on or after May 1, 2020, such 6. that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water (Regulation 7, Pan 0, Sertion ll.C.4.a.(62 Nn IStorage Tank is not subject to Rs No Yes Y Yes Y ',64-1 Continue -You have indicated th Go tothe next question You ha Go Lathe next question Source is subject to parts of Reg Is the controlled storage tank located at a well production Facility, natural gas compressor station, or natural gas processing plant constructed on or after lanuary 1, 2021or located at 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 liquids or produced water (Regulation 7, Part 0, Section ILCA.a.(2)? 40 CFR. Pert 60. Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. IS the individual sorage vessel capacity greater than or equal to 75 talc meters (m) [^'472 BBLs] (40 CFR 60.1106(a))? 2. Doesthe storage vessel meet the following exemption in 60.1t1b(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,599.974 m[F10,000 BBL] used for petroleum' or ondensate stored,processed, or treated prior to custody transfer' as defined in 60.311b? 3. Was this storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) afterJuly 23,1984 (4D CFR 60.1106(a§? 4. Does the tank meet the definition of"storage vessel"e in 60.1116? 5. Does the storage vessel store a"volatile organic liquid(VOLI'as defined in 60.111b? 6. Does thestorage vessel meet any one of the fallowing additional exemptions: a. Is ...storage vessel a pressure vessel designed to operate in excess .204.9 kna ["29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design rapacity is greater than or equalto 151 ms ['950 BBL) and stores a liquid with a maximum true vapor pressureeless than 3.5 kna (60.1106(6))?; or c. The design capacity ls greater than or equalto 75 Ne ['472 BBL] but less than 151 ma [-950 BBL] and stores a liquid with a maximumtrue vapor pressures less than 15.0 kPa(60.11nb(b))? ]. Doesthe storagetank meet either one ofthefollowing exemptions fram control requirements: a. The design capacity is greater than or equal to 151 ms ['950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa?; or b. The design capacity isgreater than or equal to 75 M' (^472 BBL] but less than 151 m' ['950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal to 15:0 kPa but less than 27.6 kna? Ia.., rook is pot subject co PISP5 Kt, D CFR. Part 60 Sub rt 0000 0000 Standards of Performancefor Crude Oil a d Natural Gas Production Transmission and Dism'bution 1. Is this storage vessel located at a facility in the onshore oil and naural gas production segment, natural gas processing segment or natural gas rransmNsion and storage segment of the industry? 2. Was thlsstorage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September., 2015? 3. Was this storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after September 18, 2015? 4. Are paten.. VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? 5. Doesthis storage vessel meet the definition of"storage vessel"' per 60.5430/60.5430a? 6. Is the storage vessel subJecLto andcontrullecsi cordancewth requi'ements for sora a vessels in 40 CFR Peet 60 Subpart kb or. CFR Part 63 Subpart HH? n ge [Note: If a rtarage vessel Is previously determined to be subject. NSPS O0OO/0O0Oa due to emissions above 6 tans per year VOC on the applicebiliry determination date, it should remain subject. NSPS 0000/00OOa 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 storagetank located at an ail and natural gas production facility that meets either of the following criteria: a. Afacility that processes, upgrades or stores hydrocarbon liquids' (63.760(')(2)); OR b. 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 delivered to afinal end user' (6.3.760(a)(3))? 2. Isthe tank located at a facility that is major' for HAPs? 3. Does the tank meet the definition of"storagevesser°in 63.]61? 4. Doesthe tank meet the definition of"storage vessel with the potential for flash emissions'per 63.]61? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? IProdused VArter titer �. Subpart A, General provisions per §63.764 (a) Table 2 §63.766- Emissions Control Standards §63.773- Monitoring 463.]74-Recordkeeping 463.775 -Reporting RAC' Review RACT review is required if Regulation] does not apply AND if the tarsi[ is In the non -attainment area. If the tank meets bath criteria, then review RACT requirements. Disclaimer MO„ x:Y-Lt''Xkx Yee Source is subject to all provlslott Go to the next question Storage Tank is not subject NSPS Continue -You have indicated th Ga to the question 4. Storage Tank Is not subject NSPS Storage Tank is not subject NSPS ontlnue - You have Indicated th Storage Tanks not subject MAC This document assists operators with determining applicability of certain requirements alba Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not e rule or regulation, and the analysis it contains may not apply to a particular situation based.upon the individual facts and circumstances. 77tis 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 Ak Quality Control Commission regulations the language of the statute or regulation will control. The use ofnon-mendatary language such as"recommend,""may,""should,"and °can,"is intended to describe APCQ 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 net establish legally binding requirements in and of itself. Section 01 -Administrative Information (Facility AIRS ID: 123 County 9C07 Plant Point 905 Section 02 - Equipment Descriptmn Details Detailed Emissions Unit ' ' '(YncAiltiadoutof Cdnderi3 Description: Emission Control Device Description: Is this loadout controlled? rged fill. are captured using a vapor batancesystem and routed; to nine (9) enclosed flares (ECf305-13)- Requested Overall VOC& HAP Control Efficiency °A: Section 03 -Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = .. Requested Permit Limit Throughput= Potential to Emit (PTE) Volume Loaded = 95 .6,3,950 Barrels (bbl) per year Barrels (bbl) per year Requested Monthly Throughput= 711,1 Barrels (bbl) per month Secondary Emissions - Combustion Device(s) Heat content of waste gas= Actual Volume of waste gas emitted per year = Requested Volume of waste gas emitted per year= Actual heat content of waste gasrouted to combustion device Requested heat content of waste gas routed to combustion device = 83,950 Barrels (bbl) per year 3514 Btu/scf scf/year . , . scf/year Potential to Emit )PTE) heat content of waste gas routed to combustion device = 5 MMBTU per year MMBTU per year ., MMBTU per year Control Device Pilot Fuel Use Rate: Pilot Fuel Gas Heating Value: 0 scfh 0 Btu/scr ::' MMscf/yr MMBTU/yr Section 04- Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Does the hydrocarbon liquid 'oaring operation utilize submerged fill? Pollutant Uncontrolled Uncontrolled Pollutant Hydrocarbon Loadout Uncontrolled Controlled (Ib/bbl) 017/bbl) (Volume Loaded) (Volume Loaded) (Ib/MMBtu) pb/bbp (waste heat combusted) (Volume Loaded) EIMI:.0.0006` 0,0630 " Pollutant Pilot Light Emissions Uncontrolled (Ib/MMBtu) Uncontrolled (Ib/MMscf) (Pilot Gas Throughput) (Waste Heat Combusted) 0,0000 0:0000 0.0000 0.0000 0.0000 Emission Factor Source Emission Factor Source Emission Factor Source .. ,• . ‘4,:r ..,ey , .. 13 of 19 C:\Users\jojones\Desktop\MINE\WWII & Gas \Syn Minor CPs for Serious \North Platte K -22\14W E0494.CP5_PA Hydrocarbon L©adout Emissions inventory 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 0.00 0.00 .,..,_ 3.00 0.00 0 0.30 IC& C.50 12.90 .0.00 3 ,;._5 0.CD 10.06 '1.00 .;. 0.02 ,_ 0 _Z .3,.32 _ 9.91 50 9.91 0.50 84 _ 9 CS 0.0& 0,.3.8 - 14 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) Ilbs/year) Benzene Toluene Ethylbenzene- XYlene n -Hexane 224 TMP 34 32 2 34 2 1 0 0 .,.-_ 302 ....-. -, _ ,r e Section 06- Reeulatory Su mmary Anal si Regulahon 3, Parts A, B Source r.=itm _s e permit Regulation 7 Part D Section II.C.5. (See regulatory applicability worksheet for detailed analysis) the hydrocarbon sirlere !oadoui source la suhle Section 07 -Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 7 Part 0 Section 01.05. Section 08 - Technical Analysis Notes The volume of waste gas routed to the ECD was calculated based on a GOR of 1.19 scf/bbl. The heat content (HHV) of waste gas was estimated at 3,514 Btu/scf. The application did not specify how these values were determined, however, since the estimated volume (0.15 MMscf/yr) is greater than the volume estimated using the default method included in this worksheet (0.12 MfAscf/yr, per calculation specified below) and the assumed HHV-is higher than the accepted value for condensate tank waste streams in the Dl Basin (2255 Btu/scf, per PS Memo 14-03, Section 5.13), the values provided by the applicant were accepted. - Method included in PA worksheet: Volume (scf/year) _ [Uncontrolled VOC (ton/year)]*(2001b/tonj/[Molecular Weight (Ib/Ib-mol)]•[379 scf/Ib-mol] MW of vapors estimated at 651b/16-mol based on AP -42 Table 7.1-2 and RVP 9liquidstored. Combustion emissions from pilot lights are accounted for in the emissions for the condensate tank, since these share comm-on control devices. Section 09 - SCC Coding and Emissions Factors (For Inventory Use Only) AIRS Point # 005 Process# SCCCode O1 4-05..002.32 ., ude Oil,? geo Uncontrolled Emissions Pollutant Factor Control % Units PM30 3.00 .0 lb/1,000 gallons transferred PM2.5 coo 0 Ib/1,000gallons transferred SOx 0.00 0 16/1,000 gallons transferred NOx 7,01 0 lb/1,000 gallons transferred VOC 5.- 95 16/1,000 gallons transferred CO _MS + lb/1,000 gallons transferred 'Benzene C.C�t. 9S lb/1,000 gallons transferred Toluene 0.^23 55 lb/1,000 gallons transferred Ethylbenzene 0_00 95 16/1,000 gallons transferred Xylene 1.00 95 16/1,000 gallons transferred n -Hexane 3.69. 9S lb/1,000 gallons transferred 224 TMP 0.00 95 lb/1,000 gallons transferred 14 of 19 C:\Users\jojones\Desktop \ MINE \TV\Oil&Gas \Syn Minor CPs for Serious \North Platte K-22\14WE0494.CP5 PA Hydrocarbon Load*. Regulatory Analysis Worksheet The regulatory requirements below ore determined posed on requested emissions and throughput. Colorado Regulation 3 Ports A and I,_APEN andPermit Requirements ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater Man TM Miegulation 3, Part A, Section IITITAIT 2. Is the loadout locatedat an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.1)? . Is Me Magnet operation beading less than 0gallons Ws BBLO Meru. dl Per day on an annual average hoc, 4. Is the Ioachut operation loading less than 6,760666 per year of condensate via splash Rlli 5. Is the loadouf operation loading gee fill procedure? 6. Are total facility uncoptrolled VOC emissions greter than 3TPY, es NOx greater Man TPY orCo emissions greater than to TPY tnegulatim 3, Part.,.cobnll.D.3)? NPALDIAIN.mCNT 1. Are uncontrolled pollutants from thisindividual so greater Marl TPY (Regulate Part A, Section ll.D.1a13 Is the load..locatergt n from andapraiuctlon site les, well pad)Me 3, Paste, Section ll.D.I.II? 3 3. Is the loadout operation loading less than 18.0.0 gallons 1238 Saki of crude oil per clay.) an annual average basis? 4. Is the loads. operation loading less than 6,760 bids per year of condensate via splash OH 5. Is the loa®utoperaon loading less than 16,388 bbls per year of condensate via submerged fill procedure, 6. Are total facility uncontrolled VOC emissions from the greater than TPY, NDx greater than s TPY orCO emissions greater than lO egulation 3, Part 3, sectonll.0.2)? of o golo aradation 7 Part Section Iles. T. Is this condensate storage rank hydrocarbon liquids lwdout located at a well producdon facility, natural gas compressor ...or natural gas pmresaing plant? 2. Does theraudily haven throughput of hydraarbon liquids loadoul to transport vehicles greater than coequal to 6,000 barrel I:Ae Section .40) -Compliance Schedule Section 6.a.(?)- Operation without Venting Seddon .a.(ni)- loadou[ Equipment operatlonantl Maintenance Section II c5 a.livl- Inadout observations and OperatorTrairfng Section ll.C,S.alvl-Records Section ILc.s.a.lvil-Requirements for Air Pollution Control Equipment Disclaimer This document assists operators with determining applicability of certain requeer ents of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is nota rule or regulation, and the analysts it contains may not apply to a particular situation based upon the Ind'dual facts and circumstances. This document,. not change or subset. for any law, regulation,) any other legally binding requirement and Is net legally enf eable. In the event of any pct between. language antis document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the Iarguage of the statute or regulation will control. The use Gen.-mandatoy language such as ,recommend,'."may.• "shodd"end Mars. is Intended to describeAPCO interpretations and recommendations. Mandatayhenninslogy such as "must" and legated' are intend. to describe controlling requirements under. terms of the Clean Air Act and Air Quality Gmtro'CommissiOn regakyians, but this document does not establish legally Mrrofrg requirements in end dntaelf. Golfo next Go to the neat x gue nest Go to stlan Go next uestion Go Sanest uestion The loadout requires a permit Got° next question. MAW. 6o to Me nogg...ion Ov Go to next question nip next question G Thetloadoutrequires a permit nnext question. Same is subject to Regulation ?Part OSection .C.6. Section 01- Administrative Information 'Facility AIRS ID: County Section 02 - Equipment Description Details Detailed Emissions Unit Description: WOODg4fgasfro�it Emission Control Device Description: etlissien atit; Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions- Separator Actual Throughput Requested Permit Limit Throughput= Potential to Emit (PTE) Throughput = Plant 013 Point dedicated enclosed flares (ECD 14-2n during WM downtime, MMscf per year MMscf per year MMscf per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL o liquids throughput: Btu/scf cf/blal Requested Monthly Throughput= f:1 MMscf per month Control Device Pilot Fuel Use Rate: Pilot Fuel Gas Heating Value: MMscf/yr Section 04- Emissions Factors & Methodologies Description heiow press IMW Helium CO2 N2 methane ethane propane isobutane n -butane isopentane n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224 TMP Benzene Toluene Ethylbenzene Xylenes C8+ Heavies Total ' VOC Wt % Weight % 4 ECDs at 18.3 scf/h r per pilot 2ighpressure separators. Overhead gas from the low4n'essure separators Ls sent to the en,.,. —spectfis gas sample dated S/1.4t2020 (analysis date 6111/202Q, 2'. 63,2IIb/Ib-mol Displacement Equaaion Ex=q*MW*Xx/C J;?l I 16 of 19 C:\Users\jojones\Desk3op\MINE\TV\Oil & Gas \Syn Minor CPs for Serious \North Platte K-22\14WE0494.CP8 PA Pollutant Separator Venting Uncontrolled (Ib/MMscf) Controlled (Ib/MMscf) Emission Factor Source =EMI= IINIUM11=1 Pollutant Pollutant Primary Control Device Uncontrolled (Ib/MMBtu) (Waste Heat Combusted) Uncontrolled Ib/MMscf ,.0075 .. (Gas Throughput) Pilot Light Emissions Uncontrolled (Ib/MMBtu) (Waste Heat Combusted) Uncontrolled Ib/MMscf '444,_.. fl=40;75 (Pilot Gas Throughput) Emission Factor Source Emission Factor Source Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM10 PM2.5 SOx NOx VOC CO _... ,,._ 0.0 0.0 GO 0.0 0.0 _._ 0.3 65 441.2 _ _0.1 - 2.418 10.1 _,08 18 e_ _-1.8 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene. Ethylbenzene Xylene n -Hexane _ 224 IMP 2252 143 2852 143 ... _ 688 _a 085 -. _ 9 24 1 24 15677 25677 1224 25677 12,84 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Part D, Section II.B, F Regulation 7, Part D, Section II.B.2.e (See regulatory applicability worksheet for detailed analysis) Source 1s subject to Regulation 7, Pa-. O, Section :1.8.2, The cm -880! device for 844 separator is net subject to Regulation 7, Part D, Section 3t.3.Z n 17 of 19 CAUsers\jojones\Desktop \ MINE \TV\Oil & Gas \Syn Minor CPs for Serious \North Platte K-22\14WE0494.CP5_PA Separator Venting Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? - This sample should represent the gas outlet of the equipment covered under this AIRS ID, and should have been collected within one year of the application received date. However, if 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 Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 40 tons per year in the ozone nonattainment area OR are emissions greater than or equal to 90 tons per year in the ozone attainment area? If yes,thepermit will contain: -An "Initial Testing Requirement" to collect a site -specific gas.sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? ye. If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 " Section OB-Technical Analysis Notes more conservative orequal. „ HHV, MW and mass itertiOns'are based on LP separator gas sample. Mass fractionsfrom thesobrce`s calculations were used, which varied slightlyfromthe sample,presuma'gedue to rounding Calculated EF's fo0Benzene and Xylene do not match apphca4on exactly, again presumably" due to rounding differences, but are within lib/yr uncontrolled. VOC emissions from pilot fights were not accouted for in the application and were not requested, These amounted to about 50Ib/yr. Section 09 - SCC Coding and Emissions Factors (For Inventory Use Only) AIRS Point # 013 Process # SCC Code 01 > ..... r,ar.� Pollutant Uncontrolled Emissions Factor Control % Units PM10 PM2.5 " 7b; R,1rv75CF SOx .r a;tmtcyz NOx ..:"°a=rcs VOC ..: MetSCt CO Benzene Toluene Ethylbenzene Xylene n -Hexane , 224 TMP 18 of 19 C:\Users\jojones\Desktop\MINE\TV\Oil & Gas \Syn Mirior [Ps for Serious \North Platte K-22\14WE0494.CP5 PA Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Re ulation 3 Parts A and B-APEN and Pennt Requirements (Source inthe Yon -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 ll.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NM, greater than to TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section I.D.3)? (You rave racketed that sous, Is in the Npn-A•a'rmsnt Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than 1TPY(Regulation 3, Part A, Section ll.D.1.a)?' 2. Are total facility uncontrolled VOC emissions from the greater than 2TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section IID.2)? Source requires a permit Colorado Regulation 7, Part D, Section 11 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after Augustl,2014? 'Source losable, to Regui,,va 7 Part O.Secr=cn,;.B.2P Section IIP.2 - General Provisions for Air Pollution Control Equipment Used to Comply with Section II Section OF- Control of emissions from well production facilities ARemative Emissions Control IOptlonal Section) a. Is this separator controlled by back-up or altemate combustion device (i.e not the primary control device) that is not enclosed? The contr,i„evice for this:=_tiara er,s not subject so Regulation ?. Part D, S.criun Section II.B,2.e -Alternative emICslons control equipment Disclaimer Yes (Source Re Ves Source Re 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 orregulation, 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 otherlegally 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 AirAct„ 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 contra/ling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. 0u rce is CDPHE gL�t. Condensate Storage Tank(s) APEN Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 14WE0494 AIRS ID Number: 123 / 9C07 /003 Section 1 - Administrative Information Company Name': Bonanza Creek Energy Operating Company, LLC Site Name: North Platte K-22 Production Facility (COGCC #433629) Site Location: NWNE, 22, 5N, 63W 40.391225, -104.421929 Mailing Address: (include zip Code) 410 17th Street, Suite 1400 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Alisson Soehner Phone Number: (303) 803-1752 E -Mail Address2: asoehner@bonanzacrkcom 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. SC COLORADO o.p.m,r.. m astir Hss1eh bEnnronmsnt Permit Number: 14WE0494 Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source AIRS ID Number: 123 /9C07/003 Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $353.13 must be submitted along with the APEN filing fee. -OR- ❑✓ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name3 El Change permit limit ❑ Transfer of ownership" ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: Requesting new throughput, emission limits, and new emission factors established using ProMax and new site specific liquid sample. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Condensate storage tank battery used to store condensate. CNDTK-01 11/30/2013 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 Storage tank(s) located at: Q Exploration Et Production (E&P) site days/week 52 weeks/year ❑ Midstream or Downstream (non E&P) si Will this equipment be operated in any NAAQS nonattainment area? Yes No D ■ Are Flash Emissions anticipated from these storage tanks? Yes No GI ■ Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? Yes No ■ p If "yes", identify the stock tank gas -to -oil ratio: m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No ■ GI Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No GI ■ eCOLORADO i� x s m nrenment Permit Number: 14WE0494 AIRS ID Number: 123 /9C07/003 Section 4 - Storage Tank(s) Information Condensate Throughput: Actual Annual Amount (bbUyear) 83,950 Requested Annual Permit Limits (bbUyear) 83,950 From what year is the actual annual amount? 2019 Average API gravity of sales oil: 44.6 degrees ❑ Internal floating roof Tank design: 0 Fixed roof RVP of sales oil: 8.3 ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) CNDTK-01 Sixteen (16) 800 bbl 12,800 10/2014 11/2013 Wells Serviced by this Storage Tank or Tank Battery6 (MP Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 37700 North Platte Federal K-O-22HNB ❑ 05 - 123 - 37732 North Platte Federal P-T-22HNB ❑ 05 - 123 - 43502 North Platte Federal 21-24-22HC ❑ 05 - 123 - 43499 North Platte Federal 31-34-22HNB ■ 05 - 123 - 43500 North Platte Federal K21-O24-22HNC ■ 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth- Requested values are required on all APENs, including APEN updates. 6 The EaP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.391225,-104.421929 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) ECD 05-13 —25 500 TBD TBD Indicate the direction of the stack outlet: (check one) 0 Upward ❑ Downward ❑ Horizontal ❑ Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) Q Circular Interior stack diameter (inches): 48 ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): COLORADO Dep.nmer. Public Ha. e .n.m-r.0 Permit Number: 14WE0494 AIRS ID Number: 123 /9C07/003 Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: 2.74 MMBtu/hr Type: Enclosed Combustor Make/Model: Five (5) Leed L30.0010 & Four (4) Leed L30-0011 Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: 500 95 98 Waste Gas Heat Content: Constant Pilot Light: El Yes ❑ No Pilot Burner Rating: 3,040 0.50 Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (EEO Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? -30 Describe the separation process between the well and the storage tanks: psig The wells produce to 3 -phase separators where condensate is separated out and routed to condensate tanks before being trucked off site. S COLORADO Department.... W.N 6 ta,mannum, Permit Number: 14WE0494 AIRS ID Number: 123 /9C07/003 Section 8 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form7. Is any emission control equipment or practice used to reduce emissions? Yes ❑ No If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) VOC ECD 95 NOx CO HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source: Pollutant Emission Factor? Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source ("� 42� Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions$ (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 10.09 lb/bbl ProMax 423.53 21.18 423.53 2118 NOx 0.088 Ib/MMBtu AP -42 0.82 0.82 0.82 0.82 CO 0.310 IbIMMBtu AP -42 3.73 3.73 3.73 3.73 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 9 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? r❑ Yes ❑ No If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: Chemical Name Chemical Abstract (CAS) Service CAS Number Emission Factor? Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions Obs/year) Controlled Emissions$ Ohs/year) Benzene 71432 0.046 lb/bbl ProMax 3,888 193 Toluene 108883 0 041 lb/bbl ProMax 3.435 172 Ethylbenzene 100414 0.0025 lb/bbl ProMax De Minimis De Minimis Xylene 1330207 0.0131 lb/bbl ProMax 1,103 55 n -Hexane 110543 0.362 lbIbbl ProMax 30,407 1.520 2,2,4-Trimethylpentane 540841 0.0079 lb/bbl ProMax 664 33 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14.03. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. COLORADO ase a nwr rwn sra`.vo+,m.m Permit Number: 14WE0494 AIRS ID Number: 123 /9C07/003 Section 10 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. t,l�wi'3'r�n- 08/03/2020 Signature of Legally Authorized Person (not a vendor or consultant) Date Alisson Soehner Environmental Engineer, Air Quality Name (print) Title Check the appropriate box to request a copy of the: Q Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $216.00 and the General Permit registration fee of $353.13, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303)692-3175 OR (303)692-3148 APCD Main Phone Number (303) 692-3150 lea COLORADO . bU ramn Maat Footnotes: 1 Attach this addendum to associated APEN form when needed to report additional wells. E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml Company Name: Source Name: Emissions Source AIRS ID2: Bonanza Creek Energy Operating Company, LLC North Platte K-22 Production Facility (COGCC# 433629) 123 / 9C07 / 003 Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 43498 North Platte Federal K31-O34-22HNC 05 - 123 - 43501 North Platte Federal P31-T34-22HC /,1 05 - 123 - 40197 North Platte Federal A-E-22HC 4 05 - 123 - 40196 North Platte Federal All-E14-22HNB /1 05 - 123 - 40195 North Platte Federal 11-14-22HNC /1 05 - 123 - 40199 North Platte Federal F11-J14-22HNB // 05 - 123 - 40198 North Platte Federal F-J-22HNC ►�I 05 - 123 - 40200 North Platte Federal F21-J24-22HNB /1 - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ z If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 APCD-212.docx CDPHE Produced Water Storage Tank(s) APEN Farm APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oit storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 14WE0494 AIRS ID Number: 123 /9C07/004 Section 1 - Administrative Information Company Name': Bonanza Creek Energy Operating Company, LLC Site Name: North Platte K-22 Production Facility (COGCC #433629) Site Location: NWNE, 22, 5N, 63W 40.391225, -104.421929 Mailing Address: (Include Zip Code) 410 17th Street, Suite 1400 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Alisson Soehner Phone Number: (303) 803-1752 E -Mail Address2: asoehner@bonanzacrk.com ' Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Li39IZ) COIOR•DO Dw.em.nx. Public Health b Enrnmment Change in equipment Change permit limit Permit Number: 14WE0494 Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source ❑ Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP05 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $353.13 must be submitted along with the APEN filing fee. -OR- AIRS ID Number: 123 / 9C07 /004 MODIFICATION to existing permit (check each box below that applies) ❑ ❑ Change company name3 Transfer of ownership4 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: emission factors. Requesting new throughput and emission limits using state 3 For company name change, a completed Company Name Change Certification Form (Form APCD 106 4 For transfer f d o ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Produced water storage tank battery used to store produced water. PWT-01 11/30/2013 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: Storage tank(s) located at: 24 hours/day 7 Exploration 8 Production (EFtP) site Will this equipment be operated in any NAAQS nonattainment area? Are Flash Emissions anticipated from these storage tanks? Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? days/week 52 weeks/year ❑ Midstream or Downstream (non EftP) site Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Are you requesting a 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions a 6 ton/yr (per storage tank)? 0 0 a Yes Yes Yes Yes Yes Yes El COLORADO Deptrow Pub. Haan 6 Envmenn-n, No N N No No Permit Number: 14WE0494 AIRS ID Number: 123 /9C07/004 Section 4 - Storage Tank(s) Information Produced Water Throughput: Actual Annual Amount (bbUyear) 54,750 Requested Annual Permit Limits (bbUyear) 54,750 From what year is the actual annual amount? Tank design: Fixed roof 2019 ❑ Internal floating roof ❑ External floating roof Storage Tank ID f! of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (monthlyear) Date of First Production (month/year) PVT -01 Two (2) 800 bbl 1,600 10/2014 11/2013 Wells Serviced by this Storage Tank or Tank Batterys (MP Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 37700 North Platte Federal K-O-22HNB ■ 05 - 123 - 37732 North Platte Federal P-T-22HNB ■ 05 - 123 - 43502 North Platte Federal 21-24-22HC ■ 05 - 123 - 43499 North Platte Federal 31-34-22HNB ■ 05 - 123 - 43500 North Platte Federal K21-O24-22HNC ❑ 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 6 The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.391225,-104-421929 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. eF) Flow Rate (ACFM) Verity (ft/sec) ECD 05-13 —25 500 TBD TBD Indicate the direction of the stack outlet: (check one) Q Upward ❑ Horizontal ❑ Downward ❑ Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) Circular Interior stack diameter (inches): 48 ❑ Square/ rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): asCOLORA00 �sp.itmm� PWtlr HWfi bEnv�ronment Permit Number: 14WE0494 AIRS ID Number: 123 /9C07/004 Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): % ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: 0.34 MMBtu/hr Type: Enclosed Combustor Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 95 % Minimum Temperature: 500 Five (5) Leed L30-0010 & Four (4) Leed L30.0011 Waste Gas Heat Content: 1,496 Btu/scf Constant Pilot Light: ❑ Yes Q No Pilot Burner Rating: N/A MMBtu/hr Description of the closed loop system: ❑ Closed Loop System ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E&I) Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? ~30 psig Describe the separation process between the well and the storage tanks: The wells produce to 3 -phase separators where produced water is separated out and routed to the produced water tanks. COLORADO Permit Number: 14WE0494 AIRS ID Number: 123 /9C07/004 Section 8 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form7. Is any emission control equipment or practice used to reduce emissions? El Yes ❑ No If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) VOC ECD 95 MDX CO RAPS ECD 95 Other: From what year is the following reported actual annual emissions data? 201 9 Use the following table to report the criteria pollutant emissions from source: Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source Mfg.,e[c Uncontrolled Emissions (tons/year) Controlled Emissions8 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 0262 lb/bbl State EF 7.17 0.36 717 036 NO. 0.0036 lb/bbl State EF 0.10 0.10 010 0 10 CO 0.0166 lb/bbl State EF 0.45 0.45 0.45 045 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 9 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? Q Yes ❑ No If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (lbs/year) Controlled Emissions$ (lbs/year) Benzene 71432 0.0070 lb/bbl AP -42 383 19 Toluene 108883 N/A N/A N/A N/A N/A Ethylbenzene 100414 N/A N/A N/A N/A N/A Xylene 1330207 N/A N/A N/A N/A N/A n -Hexane 110543 00220 lb/bbl AP -42 1.205 60 2,2,4-Trimethylpentane 540841 N/A N/A N/A N/A N/A 7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. $ Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. coLoR•oo �,a� NWtR6Enwwnmrm Permit Number: 14WE0494 AIRS ID Number: 123 /9C07/004 Section 10 - Applicant Cert�fuatlon I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. 08/03/2020 Signature of Legally Authorized Person (not a vendor or consultant) Date Alisson Soehner Environmental Engineer, Air Quality Name (print) Title Check the appropriate box to request a copy of the: QQ Draft permit prior to issuance E] Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $216.00 and the General Permit registration fee of $353.13, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303)692-3175 OR (303)692-3148 APCD Main Phone Number (303)692-3150 COLORADO fee Superseded - See attached APEN Addendum received by email on 12/11/2020. JJones - APCD Hydrocarbon Liquid Loading APEN. Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 14WE0494 AIRS ID Number: 123 / 9C07 /005 Section 1 - Administrative Information Company Name: Bonanza Creek Energy Operating Company, LLC Site Name: North Platte K-22 Production Facility (COGCC #433629) Site Location: NWNE, 22, 5N, 63W 40.391225, -104.421929 Mailing Address: (Include Zip Code) 410 17th Street, Suite 1400 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Alisson Soehner Phone Number: (303) 803-1752 E -Mail Address2: asoehner@bonanzacrk.com Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that wilt appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. COLORADO Ago Uepem.emaf Rf»u M.. b trmmmx.x Permit Number: 14WE0494 AIRS ID Number: 123 /9C07/005 Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source ❑ Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of S353.13 must be submitted along with the APEN filing fee. OR - ▪ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 Q Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) - OR ▪ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info $ Notes: emission factors. Requesting new throughput and emission limits using state 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Condensate Ioadout into tank trucks Company equipment Identification No. (optional): l_-01 For existing sources, operation began on: 12/1/2013 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Does this source load gasoline into transport vehicles? Is this source located at an oil and gas exploration and production site? If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Does this source splash fill less than 6,750 bbl of condensate per year? Does this source submerge fill less than 16,308 bbl of condensate per year? a Yes Yes Yes Yes Yes Yes Yes CI a COLORADO No No No No No No No Permit Number: 14WE0494 AIRS ID Number: 123 /9C07/005 Section 4 - Process Equipment Information Product Loaded: El Condensate ❑ Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 83,950 bbl/year Actual Volume Loaded: This product is loaded from tanks at this faci ity into: tank trucks (e.g. "rail tank cars" or "tank trucks") 83,950 bbUyear If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: Average temperature of bulk liquid loading: F True Vapor Pressure: Psia @ 60 'F Molecular weight of displaced vapors: lb/lb-mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload s Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.391225, -104.421929 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. ('F) Flow Rate (ACFM) Velocity (ft/sec) ECD 05-13 -25 500 TBD TBD Indicate the direction of the stack outlet: (check one) Upward ❑ Downward ❑ Horizontal ❑ Other (describe): Indicate the stack opening and size: (check one) 0 Circular ❑ Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): 48 Interior stack width (inches): Interior stack depth (inches): SC Depanzneni COLORADO Y ifleal.b Enm. nronn. Permit Number: 14WE0494 AIRS ID Number: 123 /9C07/005 Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Loading occurs using a vapor balance system: Requested Control Efficiency: um % O Combustion Device: Used for control of: VOC, HAPs Rating: 0.06 MMBtu/hr Type: Enclosed Combustor Make/Model: Requested Control Efficiency: 95 % Fwe (5) Leed L30-0010 b Four (4) Leed L30-0011 Manufacturer Guaranteed Control Efficiency: 98 % Minimum Temperature: 500 F Waste Gas Heat Content: 3,514 Btu/scf Constant Pilot Light: ❑ Yes No Pilot Burner Rating: N/A MMBtu/hr ❑ Other: Pollutants Controlled: Description: Requested Control Efficiency: Section 7 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? El Yes ❑ No If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6 Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SO. NO. CO VOC ECD 95 HAPs ECD 95 Other: El Using State Emission Factors (Required for GP07) ❑✓ Condensate ❑ Crude VOC Benzene n -Hexane 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source• Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source AP-42 Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissionsb (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM 40.0 ug/L AP -42 0 002 0.002 0.002 0.002 SOx 0.00022 Ib/MMBtu AP -42 <0.001 <0.001 <0.001 <0.001 NO. 0.088 Ib/MMBtu AP -42 0.02 0.02 0.02 0.02 CO 0.310 Ib/MMBtu AP -42 0.08 0.08 0.08 0.08 VOC 0.236 lb/bbl State EF 9.91 0 50 9 91 050 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. COLORADO o.ww...,n a'Mc wean*In rn,mm.n+ Permit Number: 14WE0494 AIRS ID Number: 123 /9C07/005 Section 8 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? ❑ Yes ❑ No If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions Ohs/year) Controlled Emissions6 Obslyeor) Benzene 71432 0.00041 lb/bbl State EF De Minimis De Minims Toluene 108883 N/A N/A N/A N/A N/A Ethylbenzene 100414 N/A N/A N/A N/A N/A Xylene 1330207 N/A N/A N/A N/A N/A n -Hexane 110543 0.0036 lb/bbl State EF 302 15 2,2,4-Trimethylpentane 540841 N/A N/A N/A N/A N/A Other: 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 9 - Applicant Certification 1 hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is arid will be operated in full compliance with each condition of General Permit GP07. vylrJrL- 52)/ 08/03/2020 Signature of Legally Authorized Person (not a vendor or consultant) Date Alisson Soehner Environmental Engineer, Air Quality Name (print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $216.00 and the General For more information or assistance call: Permit registration fee of $353.13, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Small Business Assistance Program (303) 692-3175 OR (303) 692-3148 APCD Main Phone Number (303)692-3150 5 16O COLORADO liAm xMal Ames X¢a1J!bEwrIrbn�nenl (APEN Addendum received by email on 12/11/2020. JJones - APCD Hydrocarbon Liquid Loading APEN Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or locks payment for the filing fee. The re -submittal will require payment for o new filing fee. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 14WE0494 AIRS ID Number: 123 / 9C07 /005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Bonanza Creek Energy Operating Company, LLC Site Name: North Platte K-22 Production Facility (COGCC #433629) Site Location: NWNE, 22, 5N, 63W 40.391225, -104.421929 Mailing Address: (Include Zip Code) 410 17th Street, Suite 1400 Site Location County: Weld NAICS or SIC Code: 1311 Denver, CO 80202 Contact Person: Alisson Soehner Phone Number: (303) 803-1752 E -Mail Addressz: asoehner@bonanzacrk.com ' Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. z Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD 208 Hydrocarbon Liquid Loading APEN Revision 07/2020 coLoRwoo 1 '°t� I �NxN�6Entiranmant Permit Number: 14WE0494 AIRS ID Number: 123 /9C07i005 [Leave biank unless APCD has already assigned a permit» and AIRS ID Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source ❑ Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $353.13 must be submitted along with the APEN filing fee. -OR- ❑✓ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑✓ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) OR - • APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: emission factors. Requesting new throughput and emission limits using state 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Condensate loadout into tank trucks Company equipment Identification No. (optional): L-01 For existing sources, operation began on: 12/1/2013 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? Yes No O ■ Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No ■ O Does this source load gasoline into transport vehicles? Yes No ■ O Is this source located at an oil and gas exploration and production site? Yes No O ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No O ■ Does this source splash fill less than 6,750 bbl of condensate per year? Yes No O ■ Does this source submerge fill less than 16,308 bbl of condensate per year? Yes No ■ O Form APCD-208 - Hydrocarbon Liquid Loading APEN Revision 07/2020 2I jelb.eiCOLORADO Department mem Antwtm Heath ntfranmant Permit Number: 14WE0494 AIRS ID Number: [Leave blank unless APCD has alread-, assigned a permit and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ❑✓ Condensate ❑ Crude Oil ❑ Other: 123 /9C07/005 If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: Actual Volume Loaded: 83,950 bbl/year This product is loaded from tanks at this facility into: (e.g. "rail tank cars" or "tank trucks") tank trucks 83,950 bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: Average temperature of bulk liquid loading: °F True Vapor Pressure: Psia ® 60 °F Molecular weight of displaced vapors: lb/lb-mot If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: fe/truckload 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM), 40.391225, -104.421929 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. ECD 05-13 -25 500 TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Downward ❑ Horizontal ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Square/rectangle ❑ Other (describe): TBD ❑ Upward with obstructing raincap Interior stack diameter (inches): 48 Interior stack width (inches): Interior stack depth (inches): Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 07/2020 A- 6-0 tot Public IAA fi Environment Permit Number: 14WE0494 AIRS ID Number: 123 /9C07/005 [Leave blank unless APCD has already assigned a permit # and AIRS ID Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑✓ Loading occurs using a vapor balance system: Requested Control Efficiency: 100 ❑ Combustion Device: Used for control of: Rating: Type: VOC, HAPs 0.06 MMBtu / h r Enclosed Combustor Make/Model: Requested Control Efficiency: 95 Five (5) Leed L30-0010 & Four (4) Leed L30-0011 Manufacturer Guaranteed Control Efficiency: 9$ Minimum Temperature: 500 °F Waste Gas Heat Content: 3,514 Btu/scf Constant Pilot Light: ❑ Yes ❑✓ No Pilot Burner Rating: N/A MMBtu/hr ❑ Other: Pollutants Controlled: Description: Requested Control Efficiency: Section 7 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO. CO VOC ECD 95 HAPs ECD 95 Other: ❑✓ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane ✓❑ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑ Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source: Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 , Uncontrolled Basis Units Source (AP -42, Mfg., etc.) uncontrolled' Emissions (tons/year) controlled Emissionsb, (Eons/year) Uncontrolled Emissions to ( , ns/year) Controlled Emissions (tons/year) PM 7.6 Ib/MMscf AP -42 0.001 0.001 0.001 0.001 SOx 0.00022 Ib/MMBtu AP -42 <0.001 <0.001 <0.001 <0.001 NO. 0.068 Ib/MMBtu AP -42 0.02 0.02 0.02 0.02 CO 0.310 Ib/MMBtu AP -42 0.08 0.08 0.08 0.08 VOC 0.236 lb/bbl State EF 9.91 0.50 9.91 0.50 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 07/2020 4I 'COLORADO n��m,Krrar+mn< �extrAtrEnvronment Permit Number: 14WE0494 AIRS ID Number: [Leave blank unless APCD has already assigned a permit k and AIRS ID] Section 8 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? If yes, use the following table to report the non cri 123 /9C07/005 ❑✓ Yes ❑ No Chemical Name Chemical ` Abstract Service (CAS) Number-: Emission Factor , ,, '; Actual Annual Emissions Uncontrolled Basis Units Source (AP 42, Mfg., etc.) Uncontrolled Emissions {lbs/year) Controlled Emissionsb ((bs/year) Benzene 71432 0.00041 lb/bbl State EF De Minimis De Minimis Toluene 108883 N/A N/A N/A N/A N/A Ethylbenzene 100414 N/A N/A N/A N/A N/A Xylene 1330207 N/A N/A N/A N/A N/A n -Hexane 110543 0.0036 lb/bbl State EF 302 15 2,2,4-Trimethylpentane 540841 N/A N/A N/A N/A N/A Other: 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. Signature of Legally Authorized Person (not a vendor or consultant) Date Alisson SOehner Environmental Engineer, Air Quality Name (print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance ✓❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $216.00 and the General Permit registration fee of $353.13, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303)692-3175 OR (303) 692-3148 APCD Main Phone Number (303) 692-3150 Form APCD-208 Hydrocarbon Liquid Loading APEN - Revision 07/2020 5 ;COLORADO Hearths ena nment 12/15/2020 State.co.us Executive Branch Mail - North Platte K-22 Permit Application STATE OF COLORADO Jones - CDPHE, Joshua loshua.jones@state.co.us> North Platte K-22 Permit Application Patrick Dilsaver <pdilsaver@slrconsulting.com> Thu, Dec 10, 2020 at 11:42 AM To: "Jones - CDPHE, Joshua" <joshua.jones@state.co.us>, Patrick Dilsaver <PDilsaver@bonanzacrk.com> Cc: Alisson Soehner <ASoehner@bonanzacrk.com> Hey Josh, I've copied responses below and also have several attachments. Let me know your thoughts. CNDTK-01 (point 003) 1. ECD emissions for NOX and CO associated with the waste gas from condensate tanks are calculated using a flow rate of 6.45 MMscf/yr and a heat content of 3040 Btu/scf. However, the model results seem to indicate that the heat content is based on Btu per actual ft3. Actual flow is indicated in the model results as 966.85 ft3/hr (8.47 MMft3/yr), compared to 736.8 scf/hr (6.45 MMscf/yr). This would result in a difference in total heat input and NOX and CO emissions as follows: Standard (736.78 scf/hr)*(3040 Btu/scf)*(MM/10^6) = 2.24 MMBtu/hr (224 MMBtu/hr) + (0.5 MMBtu/hr pilot gas) = 2.74 MMBtu/hr NOX: (0.068 Ib/MMBtu) * (2.74 MMBtu/hr) * (8760 hr/yr) / (2000 lb/ton) = 0.82 tpy CO: (0.31 Ib/MMBtu) * (2.74 MMBtu/hr) * (8760 hr/yr) / (2000 lb/ton) = 3.73 tpy Actual (966.85 ft3/hr)*(3040 Btu/ft3)*(MM/10^6) = 2.94 MMBtu/hr (2.94 MMBtu/hr) + (0.5 MMBtu/hr pilot gas) = 3.44 MMBtu/hr NOX: (0.068 Ib/MMBtu) * (3.44 MMBtu/hr) * (8760 hr/yr) / (2000 lb/ton) = 1.02 tpy CO: (0.31 Ib/MMBtu) * (3.44 MMBtu/hr) * (8760 hr/yr) / (2000 lb/ton) = 4.67 tpy Could you please verify for me if the heating value in the ProMax model results are in standard or actual cubic feet and whether emissions should be revised as I have indicated above? Hey Josh, I wasn't sure if the value in ProMax is btu/scf or btu/actual ft3. I performed the following "check" against the Liquid heating value given in Btu/lb in the sane report; 21,056.3 (Btu/lb) * 54.3754 (Ib/Ibmol) / 379.3 (scf/Ibmol) = 3,019 Btu/scf This should calculate the heat content in Btu/scf as a check, and is 0.7% difference from the 3,040 number I assumed was in Btu/scf. I think this is a small enough difference to confirm that the model value is actually in Btu/scf, what do you think? If not we can discuss further on possible redlines. If it was in Btu/acf, I would think we would see a difference more along the — 24% seen in acf vs. scf flow. rates you pointed out above. If emissions need to be revised please submit a revised calculation sheet and I can red -line the APEN and send you a copy. https://mail.google.com/mail/u/0?ik=6fb81 abf08&view=pt&search=all&permmsgid=msg-f%3A1685717794784517340&simpl=msg-f%3A168571779478... 1/3 12/15/2020 State.co.us Executive Branch Mail - North Platte K-22 Permit Application 2. Could you please submit an APEN Addendum form for E&P Storage Tanks (Form APCD-212) identifying the additional wells associated with this facility? Five wells were reported on the APEN, but I didn't see that the other eight were reported in this application. I can include the form in our records for the produces water tanks as well. See attached, we included this in the original application for the new wells, forgot to include it here. Do I need to alter the form so it doesn't state "newly reported", or will this suffice? LPGFL-01 (point 013 3. NOX and CO emissions from the combustion of pilot gas fuel associated with natural gas venting from the low pressure separators should be included with those from waste gas combustion for an accurate accounting of these emissions from this source. Assuming 4 pilot lights with the same pilot gas flowrate as those of the other ECDs (18.3 scf/hr) this would increase NOX emissions by about 0.08 tpy for a total of 0.39 tpy, and increase CO emissions by about 0.36 tpy, for a total of 1.78 tpy. If you agree please submit an updated calculation sheet that includes NOX and CO emissions for this point from pilot gas combustion and I can red -line the APEN and send you a copy. We agree and please find attached an updated calculation sheet PM Emissions 4. The Division agrees with BCEOC's use of the 40.0 Ng/L emission factor (AP -42 Table 13.5-1) for the ECDs and the fact that this is a conservative estimate since the ECDs at this facility are a smokeless design. But I was not able to determine how emissions were calculated using the factor. Specifically, could you explain how (scf CH4/hr) was determined and where the conversion factor of (10.6 scf E/scf CH4) is from? I could not find where this calculation methodology was from. I've been trying to switch to 7.6 Ib/MMscf which we were told was the preferred AP -42 emission factor, and would prefer to redline the TLO and Condenstate tank combustion emissions to this emission factor. I've attached proposed calculation sheets, do you agree with this? SLR°1 Patrick Dilsaver 970-494-0805 970-494-0805 307-214-9584 pdilsaver@slrconsulting.com SLR International Corporation 143 Union Blvd, Suite 505, Lakewood, CO 80228 Confidentiality Notice and Disclaimer This communication and any attachment(s) contain information which is confidential and may also be legally privileged. It is intended for the exclusive use of the recipient(s) to whom it is addressed. If you have received this communication in error, please e-mail us by return e-mail and then delete the e-mail from your system together with any copies of it. Any views or opinions are solely those of the author and do not represent those of SLR Management Ltd, or any of its subsidiaries, unless specifically stated. From: Jones - CDPHE, Joshua <joshua.jones@state.co.us> Sent: December 08, 2020 4:28 PM [Quoted text hidden] [Quoted text hidden] 3 attachments https://mail.google.com/mail/u/0?ik=6fb81abf08&view=pt&search=a 2/3 12/15/2020 State.co.us Executive Branch Mail - North Platte K-22 Permit Application ' NP K-22 Well addendum form.pdf 79K NPK22_50 tpy Mod_20201210_CNDTK and TLO redlines.pdf 75K • NPK22_50 tpy Mod_20201210_LPGFL Redlines.pdf 71K https://mail.google.com/mail/u/0?ik=6fb81 abf08&view=pt&search=all&permmsgid=msg-f%3A1685717794784517340&simpl=msg-f%3A168571779478... 3/3 12/15/2020 State.co.us Executive Branch Mail - North Platte K-22 Permit Application STATE OF COLORADO Jones - CDPHE, Joshua <joshua.jones@state.co.us> North Platte K-22 Permit Application Jones - CDPHE, Joshua <joshua.jones@state.co.us> Fri, Dec 11, 2020 at 8:41 AM To: Patrick Dilsaver <pdilsaver@slrconsulting.com> Cc: Patrick Dilsaver <PDilsaver@bonanzacrk.com>, Alisson Soehner <ASoehner@bonanzacrk.com> Patrick, Attached is draft 14WE0494 for your review. This one is also going through internal review and so may have a few changes that I will notify you about before public notice. This has incorporated your responses to my questions. Per your responses above, For CNDTK-01 (point 003) • We will presume the heating value is Btu/scf. I used liquid Btu/lb and mass flow lb/hr and it also came out closer to the numbers you had originally submitted. • It's ok the addendum has checks as "newly reported". For PM emissions the 7.6 Ib/MMscf EF is great. Let me know if you have any questions. Thanks much, Joshua Jones Permit Engineer Title V Operating Permit Unit Stationary Sources Program COLORADO Air Pollution Control Division Department of Pl'oLe Health 6 Environment P 303.692.3207 I F 303.782.5493 4300 Cherry Creek Drive South, Denver, CO 80246-1530 joshuajones@stateco.us I www.colorado.gov/cdphe/apcd Questions on Air Pollution Control Division operations during COVID-19 response? Visit our FAQ Page. Are you curious about ground -level ozone in Colorado? Visit our ozone webpage to learn more. [Quoted text hidden] 14WE0494.CP5_DRAFT.docx 202K https://mail.google.com/mail/u/0?ik=6fb81 abf08&view=pt&search=all&permmsgid=msg-a%3Ar1652675976306596532&simpl=msg-a%3Ar165267597... 1/1 12/15/2020 State.co.us Executive Branch Mail - North Platte K-22 Permit Application STATE OF COLORADO Jones - CDPHE, Joshua <joshua.jones@state.co.us> North Platte K-22 Permit Application Leah Althoff <lalthoff@slrconsulting.com> Fri, Dec 11, 2020 at 3:26 PM To: Patrick Dilsaver <pdilsaver@slrconsulting.com>, "Jones - CDPHE, Joshua" <joshua.jones@state.co.us>, Patrick Dilsaver <PDilsaver@bonanzacrk.com> Cc: Alisson Soehner <asoehner@bonanzacrk.com> Attached APENs for the LPGFL and TLO. No place to report PM on the CNDTK APEN so I did not include it. Thanks! SLR Leah Althoff 970-999-3978 970-494-0805 612-770-3941 lalthoff@slrconsulting.com SLR International Corporation 1612 Specht Point Road, Suite 119, Fort Collins, CO 80525 Confidentiality Notice and Disclaimer This communication and any attachment(s) contain information which is confidential and may also be legally privileged. It is intended for the exclusive use of the recipient(s) to whom it is addressed. If you have received this communication in error, please e-mail us by return e-mail and then delete the e-mail from your system together with any copies of it. Any views or opinions are solely those of the author and do not represent those of SLR Management Ltd, or any of its subsidiaries, unless specifically stated. From: Patrick Dilsaver <pdilsaver@slrconsulting.com> Sent: December 11, 2020 9:01 AM To: Jones - CDPHE, Joshua <joshua.jones@state.co.us>; Patrick Dilsaver <PDilsaver@bonanzacrk.com>; Patrick Dilsaver <pdilsaver@slrconsulting.com> Cc: Alisson Soehner <asoehner@bonanzacrk.com>; Leah Althoff <lalthoff@slrconsulting.com> Subject: FW: North Platte K-22 Permit Application Thanks Josh we will look this draft permit over and get updated APENs for the LPGFL, CNDTK and TLO. I am only in the office this morning. I copied Leah Althoff who is going to work to send over those APENs later today. https://mail.google.com/mail/u/0?ik=6fb81 abf08&view=pt&search=all&permmsgid=msg-f%3A1685822519274827561 &simpl=msg-f%3A 168582251927... 1/2 12/15/2020 Have a great weekend, Pat Patrick Dilsaver 970-494-0805 970-494-0805 307-214-9584 pdilsaver@sIrconsulting.com SLR International Corporation 143 Union Blvd, Suite 505, Lakewood, CO 80228 State.co.us Executive Branch Mail - North Platte K-22 Permit Application From: Jones - CDPHE, Joshua <joshua.jones@state.co.us> [Quoted text hidden] [Quoted text hidden] 2 attachments APEN 211_20201211.pdf 281K APEN 208_20201211.pdf 297K https://mail.google.com/mail/u/0?ik=6fb81abf08&view=pt&sea rch=all&permmsg id=msg-f%3A 1685822519274827561&simpl=msg-f%3A 168582251927... 2/2 Bonanza Creek Energy Operating Company, LLC. - North Platte K-22 Production Facility (COGCC #433629) Enclosed Combustion Device (ECD) Emission Calculations for Truck Loadout Emission Source: Truck Loadout Source Type: ECD Heat Input: 0.06 MMBtu/hr Gas Oil Ratio (GOR): 1.79 scf/bbl Tank Vent Gas Flowrate: 17.1 scf/hr Tank Vent Gas Flowrate: 0.15 MMscf/yr Estimated HHV: 3,514 Btu/scf Sulfur Content of Fuel: 0.0020 gr/scf Operating Hours per Year: 8,760 hr/yr Pollutant Emission Factors or Uncontrolled Emissions (a) Emissions lb/hr (14 (c) tpy (d) COP) 116.98 1b/MMBtu 7.05 30.87 N2O 0.00022 Ib/MMBtu 0.000 0.000 NOx 0.068 Ib/MMBtu 0.004 0.02 CO 0.310 Ib/MMBtu 0.02 0.08 SO2 0.000161b/MMBtu 0.000 0.000 • PK° 7.6 Ib/MMscf 0.000 0.001 PM2.5 7.6 Ib/MMscf 0.000 0.001 Notes: (a) Emission factors are from AP -42 Tables 13.5-1 & 2 (Industrial Flares) SO2 emissions based on AP42, which is based on 100% conversion of sulfur to SO2 at 2000 grains/MMscf. N2O emission factor from 40 CFR Part 98 Table C-2 for Natural Gas. (b) Hourly Emission Rate (lb/hr) except for PK() = (Emission Factor, Ib/MMBtu) * (Heat Input, MMBtu/hr) (c) lb PM10 / hr = 7.6 (Ib/MMscf) * (scf/hr) / 1e6 (scf/MMscf) (d) Annual Emission Rate (tpy) _ (Hourly Emission Rate, lb/hr) * (hr/yr) / (2,000 lb/ton) (e) This represents CO2 as a product of combustion. It is calculated using equation W-21 of 40 CFR Part 98 Superseded - See attached APEN Addendum received by email on 12/11/2020. JJones - APCD Gas Venting APEN - Form APCD-,2,11 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 14WE0494 AIRS ID Number: 123 / 9C07 /013 Section 1 - Administrative Information Company Name': Bonanza Creek Energy Operating Company, LLC Site Name: North Platte K-22 Production Facility (COGCC #433629) Site Location: NWNE, 22, 5N, 63W 40.391225, -104.421929 Mailing Address: 410 17th Street, Suite 1400 (Include Zip Code) Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Alisson Soehner Phone Number: (303) 803-1752 E -Mail Address2: asoehner@bonanzacrkcorn ' Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. z Permits, exemption letters, and any processing invoices will be issued by the APCD via email to the address provided. Cn,OLORDO wmnm. d Awar HeW� Y Cnr:.onmsro Permit Number: 14WE0494 Section 2 - Requested Action AIRS ID Number: 123 / 9co7 / 013 ❑ NEW permit OR newly -reported emission source -OR- Q MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit (] Change permit limit ❑ Transfer of ownership° ❑ Other (describe below) - OR APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PER/AIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: Requesting new throughput and emission limits using updated emission factors based on a site specific gas analysis obtained June 2020. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General information General description of equipment and purpose: combustion devices. Low pressure separator gas controlled by enclosed Company equipment Identification No. (optional): For existing sources, operation began on: LPGFL 12/1/2013 For new, modified, or reconstructed sources, the projected start-up date is: El Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: 24 Will this equipment be operated in any NAAQS nonattainment area? hours/day 7 Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? days/week 52 weeks/year Yes ❑ Yes ✓❑ Yes ❑ No 0 No ❑ No COl0RA00 n+'Wrt-ewtMA�blx NeMth 6 Enn,onmen, Permit Number: 14WE0494 AIRS ID Number: 123 /9c07/ 013 Section 4 - Process Equipment Information ID Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ No Vent Gas 3 635 BTU/SCF Heating Value: Requested: 2.50 MMSCF/year Actual: 2.550 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 63.2 VOC (weight %) 96.4923 Benzene (weight %) 0.6840 Toluene (Weight %) 0.1642 Ethylbenzene (weight %) 0.0021 Xylene (Weight %) 0.0057 n -Hexane (Weight %) 6.1585 2,2,4-Trimethylpentane (Weight %) 0.0012 Additional Required Documentation: El Attach a representative gas analysis (including BTEX lx n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX a n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. COLORADO Nero. n em,mean.v Permit Number: 14WE0494 Section 5 - Geographical/Stack Information AIRS ID Number: 123 /9C07/O13 Geographical Coordinates (Latitude/Longitude or UTM) 40.391225, -104.421929 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stack ID No. Discharge Height Above Level (Feet) Temp. (' F) Flow Rate (ACFM) Velocity (ft/sec) ECD 14-17 -25 500 TBD TBD Indicate the direction of the stack outlet: (check one) Ei Upward ❑ Downward ❑ Horizontal ❑ Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter (inches): 48 ❑ Square/rectangle Interior stack width (inches): ❑ Other (describe): Interior stack depth (inches): Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Size: Make/Model: ■ VRU: Requested Control Efficiency: % VRU Downtime or Bypassed: % Pollutants Controlled: VOC, HAPs Rating: 1.04 MMBtu/hr Combustion Type: Enclosed Combustor Make/Model: Four (4) Leed L30-0011 III Requested Control Efficiency: 95 % Device: Manufacturer Guaranteed Control Efficiency: 98 % Minimum Temperature: 500 Waste Gas Heat Content: 3,635 Btu/scf Constant Pilot Light: ■ Yes • No Pilot burner Rating: NSA MMBtu/hr Pollutants Controlled: ■ Other: Description: Requested Control Efficiency: % goCOLORADO Department a1 V404e NeMth 0 Fnmmnment Permit Number: 14WE0494 AIRS ID Number: 123 /9O07/ 013 Section 7 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? Q Yes ❑ No If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or combined values if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Description Overall Requested Control Efficiency (x reduction in emissions) PM SO. NO. CO VOC ECD 95 HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? 2019 o report the criteria pollutant emissions from source: Pollutant ✓ Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source ('� 42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM 7.6 Ib/MMscf AP -42 0.01 0.01 0.01 0.01 SOx <0.0001 Ib/MMBtu AP -42 <0.0001 <0.0001 <0.0001 <0.0001 NO. 0.068 Ib/MMBtu AP -42 0.31 0.31 0.31 0.31 CO 0.310 Ib/MMBtu AP -42 1.42 142 1.42 1.42 VOC 160,921 91 Ib/MMscf Gas Analysis 201.16 10.06 201.16 10.06 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 8 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? 0 Yes ❑ No e to resort the non -criteria pollutant CHAP) emissions from source: ,- - - Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (lbs/year) Controlled Emissions (lbs/year) Benzene 71432 1.140.72 lb/MMscf Gas Analysis 2,852 143 Toluene 108883 273.84 Ib/MMsef Gas Analysis 685 34 Ethylbenzene 100414 3.50 Ib/MMscf Gas Analysis De Minimis De Minimis Xylene 1330207 9.51 Ib/MMscf Gas Analysis De Minimis De Minimis n -Hexane 110543 10.270.64 Ib/MMscf Gas Analysis 25,677 1.284 2,2,4-Trimethylpentane 540841 2.00 Ib/MMscf Gas Analysis De Minimis De Minimis Other: _ 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. + COLORADO a wu« !N A.b CflvfronYnMt Permit Number: 14WE0494 AIRS ID Number: 123 /9C07/O13 Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 08/03/2020 Signature of Legally Authorized Person (not a vendor or consultant) Date Alisson Soehner Environmental Engineer, Air Quality Name (print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $216.00 to: For more information or assistance call: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Small Business Assistance Program (303)692-3175 OR (303)692.314$ APCD Main Phone Number Make check payable to: (303)692-3150 Colorado Department of Public Health and Environment COLORADO xeal Department [� �me�t APEN Addendum received by email on 12/11/2020. JJones - APCD Gas Venting APEN - Farm APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 14WE0494 AIRS ID Number: 123 i 9C07 /013 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Bonanza Creek Energy Operating Company, LLC Site Name: North Platte K-22 Production Facility (COGCC #433629) Site Location: NWNE, 22, 5N, 63W 40.391225, -104.421929 Mailing address: 410 17th Street Suite 1400 (Include Zip Code) Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address2: Alisson Soehner (303) 803-1752 asoehner@bonanzacrk.com I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. z Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-211 - Gas Venting APEN - Revision 07/2020 ;COLORADO 1 I Department. " Et� ar t Permit Number: 14WE0494 AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] 123 / 9co7 /013 Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source -OR - ❑✓ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit p Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info £t Notes: Requesting new throughput and emission limits using updated emission factors based on a site specific gas analysis obtained June 2020. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: combustion devices. Low pressure separator gas controlled by enclosed Company equipment Identification No. (optional): For existing sources, operation began on: LPGFL 12/1/2013 For new, modified, or reconstructed sources, the projected start-up date is: ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: 24 Will this equipment be operated in any NAAQS nonattainment area? hours/day 7 Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? days/week 52 weeks/year ❑✓ Yes ❑ Yes ❑✓ Yes Form APCD-211 Gas Venting APEN - Revision 07/2020 2 ❑ No ❑✓ No ❑ No COLORADO a q�msan�,�, Permit Number: 14WE0494 AIRS ID Number: 123 /9c07/013 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑r Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ No Vent Gas 3 635 BTU/SCF Heating Value: Requested: 2.50 MMSCF/year Actual: 2.50 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 63.2 VOC (Weight %) 96.4923 Benzene (Weight %) 0.6840 Toluene (Weight %) 0.1642 Ethylbenzene (Weight %) 0.0021 Xylene (Weight %) 0.0057 n -Hexane (Weight %) 6.1585 2,2,4-Trimethylpentane (Weight %) 0.0012 Additional Required Documentation: El Attach a representative gas analysis (including BTEX Ft n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX ft n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. Form APCD-211 Gas Venting APEN • Revision 07/2020 y�► COLORADO 3 N� xnnneEnwanmma Permit Number: 14WE0494 AIRS ID Number: 123 / 9co7 / 013 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.391225, -104.421929 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stack ID No. h H h Discarge Height Above Ground Level (Feet) Temp , . ( F) .. z . d ECD 14-17 -25 500 TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Downward ❑ Horizontal ❑ Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) ✓❑ Circular Interior stack diameter (inches): 48 ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: ❑ Combustion Device: Pollutants Controlled: V®C HAPs Rating: 1.31 MMBtu/hr Type: Enclosed Combustor Make/Model: Four (4) Leed L30-0011 Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: 500 Waste Gas Heat Content: 3,835 Btu/scf Constant Pilot Light: ❑ Yes ❑✓ No Pilot burner Rating: NSA MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 07/2020 ORADO m w Public r Envltonment Permit Number: 14WE0494 AIRS ID Number: 123 9C07,1 013 [Leave blank unless APCD has already assigned a permit # and AIRS ID] R Section 7 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO), CO VOOC ECD 95 HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source: Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis .,7.6 Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissionsb (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tonslyear) PM Ib/MMscf AP -42 0.02 0.02 0.02 0.02 SOx <0.0001 Ib/MMBtu AP -42 <0.0001 <0.0001 <0.0001 <0.0001 NOx 0.068 Ib/MMBtu AP -42 0.39 0.39 0.39 0.39 CO 0.310 Ib/MMBtu AP -42 1.78 1.78 1.78 1.78 VOC 160,921.91 Ib/MMscf Gas Analysis 201.16 10.06 201.16 10.06 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 8 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc. Uncontrolled Emissions tbsl ear ( y ) Controlled b Emissions Ohs/year) Benzene 71432 1,140.72 Ib/MMscf Gas Analysis 2,852 143 Toluene 108883 273.84 Ib/MMscf Gas Analysis 685 34 Ethylbenzene 100414 3.50 Ib/MMscf Gas Analysis De Minimis De Minimis Xylene 1330207 9.51 Ib/MMscf Gas Analysis De Minimis De Minimis n -Hexane 110543 10,270.64 Ib/MMscf Gas Analysis 25,677 1,284 2,2,4-Trimethylpentane 540841 2.00 Ib/MMscf Gas Analysis De Minimis De Minimis Other: ❑✓ Yes ❑ No 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Form APCD-211 - Gas Venting APEN - Revision 07/2020 5 ICS .f3RADO Mxp.-0te • Health;v47.mMnl Permit Number: 14WE0494 AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification 123 / 9co7 013 I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. Signature of Legally Authorized Person (not a vendor or consultant) Date Alisson Soehner Environmental Engineer, Air Quality Name (print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance �✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $216.00 to: For more information or assistance call: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Small Business Assistance Program (303)692-3175 OR (303)692-3148 APCD Main Phone Number Make check payable to: (303) 692-3150 Colorado Department of Public Health and Environment Form APCD-211 - Gas Venting APEN - Revision 07/2020 6 ICOLORADO Department atPublic 7i ea666Env6amaent 12/15/2020 State.co.us Executive Branch Mail - North Platte K-22 Permit Application STATE OF COLORADO North Platte K-22 Permit Application Jones - CDPHE, Joshua <joshua.jones@state.co.us> Patrick Dilsaver <pdilsaver@slrconsulting.com> Thu, Dec 10, 2020 at 11:42 AM To: "Jones - CDPHE, Joshua" <joshua.jones@state.co.us>, Patrick Dilsaver <PDilsaver@bonanzacrk.com> Cc: Alisson Soehner <ASoehner@bonanzacrk.com> Hey Josh, I've copied responses below and also have several attachments. Let me know your thoughts. CNDTK-01 (point 003) 1. ECD emissions for NOX and CO associated with the waste gas from condensate tanks are calculated using a flow rate of 6.45 MMscf/yr and a heat content of 3040 Btu/scf. However, the model results seem to indicate that the heat content is based on Btu per actual ft3. Actual flow is indicated in the model results as 966.85 ft3/hr (8.47 MMft3/yr), compared to 736.8 scf/hr (6.45 MMscf/yr). This would result in a difference in total heat input and NOX and CO emissions as follows: Standard (736.78 scf/hr)*(3040 Btu/scf)*(MM/10^6) = 2.24 MMBtu/hr (2.24 MMBtu/hr) + (0.5 MMBtu/hr pilot gas) = 2.74 MMBtu/hr NOX: (0.068 Ib/MMBtu) * (2.74 MMBtu/hr) * (8760 hr/yr) / (2000 lb/ton) = 0.82 tpy CO: (0.31 Ib/MMBtu) * (2.74 MMBtu/hr) * (8760 hr/yr) / (2000 lb/ton) = 3.73 tpy Actual (966.85 ft3/hr)*(3040 Btu/ft3)*(MM/10^6) = 2.94 MMBtu/hr (2.94 MMBtu/hr) + (0.5 MMBtu/hr pilot gas) = 3.44 MMBtu/hr NOX: (0.068 Ib/MMBtu) * (3.44 MMBtu/hr) * (8760 hr/yr) / (2000 lb/ton) = 1.02 tpy CO: (0.31 Ib/MMBtu) * (3.44 MMBtu/hr) * (8760 hr/yr) / (2000 lb/ton) = 4.67 tpy Could you please verify for me if the heating value in the ProMax model results are in standard or actual cubic feet and whether emissions should be revised as I have indicated above? Hey Josh, I wasn't sure if the value in ProMax is btu/scf or btu/actual ft3. I performed the following "check" against the Liquid heating value given in Btu/lb in the same report; 21,056.3 (Btu/lb) * 54.3754 (Ib/Ibmol) / 379.3 (scf/Ibmol) = 3.019 Btu/scf This should calculate the heat content in Btu/scf as a check, and is 0.7% difference from the 3,040 number I assumed was in Btu/scf. I think this is a small enough difference to confirm that the model value is actually in Btu/scf, what do you think? If not we can discuss further on possible redlines. If it was in Btu/acf, I would think we would see a difference more along the - 24% seen in acf vs. scf flow rates you pointed out above. If emissions need to be revised please submit a revised calculation sheet and I can red -line the APEN and send you a copy. https://mail.google.com/mail/u/0?ik=6fb81 abf08&view=pt&search=all&permmsgid=msg-f%3A1685717794784517340&simpl=msg-f%3A168571779478... 1/3 12/15/2020 State.co.us Executive Branch Mail - North Platte K-22 Permit Application 2. Could you please submit an APEN Addendum form for E&P Storage Tanks (Form APCD-212) identifying the additional wells associated with this facility? Five wells were reported on the APEN, but I didn't see that the other eight were reported in this application. I can include the form in our records for the produces water tanks as well. See attached, we included this in the original application for the new wells, forgot to include it here. Do I need to alter the form so it doesn't state "newly reported", or will this suffice? LPGFL-01 (point 013) 3. NOX and CO emissions from the combustion of pilot gas fuel associated with natural gas venting from the low pressure separators should be included with those from waste gas combustion for an accurate accounting of these emissions from this source. Assuming 4 pilot lights with the same pilot gas flowrate as those of the other ECDs (18.3 scf/hr) this would increase NOX emissions by about 0.08 tpy for a total of 0.39 tpy, and increase CO emissions by about 0.36 tpy, for a total of 1.78 tpy. If you agree please submit an updated calculation sheet that includes NOX and CO emissions for this point from pilot gas combustion and I can red -line the APEN and send you a copy. We agree and please find attached an updated calculation sheet PM Emissions 4. The Division agrees with BCEOC's use of the 40.0 pg/L emission factor (AP -42 Table 13.5-1) for the ECDs and the fact that this is a conservative estimate since the ECDs at this facility are a smokeless design. But I was not able to determine how emissions were calculated using the factor. Specifically, could you explain how (scf CH4/hr) was determined and where the conversion factor of (10.6 scf E/scf CH4) is from? I could not find where this calculation methodology was from. I've been trying to switch to 7.6 lb/11/1Mscf which we were told was the preferred AP -42 emission factor, and would prefer to redline the TLO and Condenstate tank combustion emissions to this emission factor. I've attached proposed calculation sheets, do you agree with this? SLR°1 Patrick Dilsaver 970-494-0805 970-494-0805 307-214-9584 pdilsaver@slrconsulting.com SLR International Corporation 143 Union Blvd, Suite 505, Lakewood, CO 80228 Confidentiality Notice and Disclaimer This communication and any attachment(s) contain information which is confidential and may also be legally privileged. It is intended for the exclusive use of the recipient(s) to whom it is 'addressed. If you have received this communication in error, please e-mail us by return e-mail and then delete the e-mail from your system together with any copies of it. Any views or opinions are solely those of the author and do not represent those of SLR Management Ltd, or any of its subsidiaries, unless specifically stated. From: Jones - CDPHE, Joshua <joshua.jones@state.co.us> Sent: December 08, 2020 4:28 PM [Quoted text hidden] [Quoted text hidden] 3 attachments https://mail.google.com/mail/u/0?ik=6fb81 abf08&view=pt&search=all&permmsgid=msg-f%3A1685717794784517340&simpl=msg-f%3A 168571779478... 2/3 12/15/2020 State.co.us Executive Branch Mail - North Platte K-22 Permit Application NP K-22 Well addendum form.pdf 79K NPK22_50 tpy Mod_20201210_CNDTK and TLO redlines.pdf 75K mjhb NPK22_50 tpy Mod_20201210_LPGFL Redlines.pdf 71K https://mail.google.com/mail/u/0?ik=6fb81 abf08&view=pt&search=all&permmsgid=msg-f%3A1685717794784517340&simpl=msg-f%3A168571779478... 3/3 12/15/2020 State.co.us Executive Branch Mail - North Platte K-22 Permit Application STATE OF COLORADO Jones - CDPHE, Joshua <joshua.jones@state.co.us> North Platte K-22 Permit Application Jones - CDPHE, Joshua <joshua.jones@state.co.us> Fri, Dec 11, 2020 at 8:41 AM To: Patrick Dilsaver <pdilsaver@slrconsulting.com> Cc: Patrick Dilsaver <PDilsaver@bonanzacrk.com>, Alisson Soehner <ASoehner@bonanzacrk.com> Patrick, Attached is draft 14WE0494 for your review. This one is also going through internal review and so may have a few changes that I will notify you about before public notice. This has incorporated your responses to my questions. Per your responses above, For CNDTK-01 (point 003) • We will presume the heating value is Btu/scf. I used liquid Btu/lb and mass flow lb/hr and it also came out closer to the numbers you had originally submitted. • It's ok the addendum has checks as "newly reported". For PM emissions the 7.6 Ib/MMscf EF is great. Let me know if you have any questions. Thanks much, Joshua Jones Permit Engineer Title V Operating Permit Unit Stationary Sources Program COLORADO Air Pollution Control Division Department of Public Health 6 Environment P 303.692.3207 F 303.782.5493 4300 Cherry Creek Drive South, Denver, CO 80246-1530 joshua.jones@state.co.us I www.colorado.gov/cdphe/apcd Questions on Air Pollution Control Division operations during COVID-19 response? Visit our FAQ Page. Are you curious about ground -level ozone in Colorado? Visit our ozone webpage to learn more. [Quoted text hidden] 14W E0494.C P5_DRAFT.docx 202K https://mail.google.com/mail/u/0?ik=6fb81 abf08&view=pt&search=all&permmsgid=msg-a%3Ar1652675976306596532&simpl=msg-a%3Ar165267597... 1/1 12/15/2020 State.co.us Executive Branch Mail - North Platte K-22 Permit Application STATE OF COLORADO Jones - CDPHE, Joshua <joshua.jones@state.co.us> North Platte K-22 Permit Application Leah Althoff <lalthoff@slrconsulting.com> Fri, Dec 11, 2020 at 3:26 PM To: Patrick Dilsaver <pdilsaver@slrconsulting.com>, "Jones - CDPHE, Joshua" <joshua.jones@state.co.us>, Patrick Dilsaver <PDilsaver@bonanzacrk.com> Cc: Alisson Soehner <asoehner@bonanzacrk.com> Attached APENs for the LPGFL and TLO. No place to report PM on the CNDTK APEN so I did not include it. Thanks! SLR` Leah Althoff 970-999-3978 970-494-0805 612-770-3941 lalthoff@sIrconsulting.com SLR International Corporation 1612 Speoht Point Road; Suite 119, Fort Collins, CO 80525 Confidentiality Notice and Disclaimer This communication and any attachment(s) contain information which is confidential and may also be legally privileged. It is intended for the exclusive use of the recipient(s) to whom it is addressed. If you have received this communication in error, please e-mail us by return e-mail and then delete the e-mail from your system together with any copies of it. Any views or opinions are solely those of the author and do not represent those of SLR Management Ltd, or any of its subsidiaries, unless specifically stated. From: Patrick Dilsaver <pdilsaver@slrconsulting.com> Sent: December 11, 2020 9:01 AM To: Jones - CDPHE, Joshua <joshua.jones@state.co.us>; Patrick Dilsaver <PDilsaver@bonanzacrk.com>; Patrick Dilsaver <pdilsaver@slrconsulting.com> Cc: Alisson Soehner <asoehner@bonanzaork.com>; Leah Althoff <lalthoff@slroonsulting.com> Subject: FW: North Platte K-22 Permit Application Thanks Josh we will look this draft permit over and get updated APENs for the LPGFL, CNDTK and TLO. I am only in the office this morning. I copied Leah Althoff who is going to work to send over those APENs later today. https://mail.google.com/mail/u/0?ik=6fb81 abf08&view=pt&search=all&permmsgid=msg-f%3A1685822519274827561 &simpl=msg-f%3A168582251927... 1/2 12/15/2020 Have a great weekend, Pat Patrick Dilsaver 970-494-0805 970-494-0805 -' 307-214-9584 pdilsaver@slrconsulting.com State.co.us Executive Branch Mail - North Platte K-22 Permit Application SLR International Corporation 143 Union Blvd, Suite 505, Lakewood, CO 80228 From: Jones - CDPHE, Joshua <joshua.jones@state.co.us> [Quoted text hidden] [Quoted text hidden] 2 attachments APEN 211_20201211.pdf 281K i APEN 208_20201211.pdf 4-1 297K https://mail.google. com/mail/u/0?ik=6fb81 abf08&view=pt&search=all&permmsgid=msg-f%3A1685822519274827561 &simpl=msg-f%3A16858?251927... 2/2 Bonanza Creek Energy Operating Company, LLC. - North Platte K-22 Production Facility (COGCC #433629) Low Pressure Gas Flaring Emission Calculations Source Type: Enclosed Flare Heat Input: 1.31 MMBtu/hr LP Separator Gas Annual Flow Rate tat: 2.50 MMscf/yr LP Separator Gas to Oil Ratio: 29.78 scf/bbl Average Hourly Flowrate tat: 285.4 scf/hr Total Annual Flowrate: 2.50 MMscf/yr Pilot Gas Flowrate: 18.3 scf/hr Pilot Gas Flowrate: 0.16 MMscf/yr Total Enclosed Combustors: 4 Flowrate to Combustor Including Pilot: 358.6 scf/hr Flowrate to Combustor Including Pilot: 3.14 MMscf/yr Estimated HHV (b): 3,635 Btu/scf Enclosed Flare VOC Control Efficiency: 95% Molecular Weight (b): 63.2 Ib/Ib-mol H2S Content of Fuel (b): 0.0 ppm H2S Operating Hours: 8,760 hr/yr Pollutant Emission Factors (`) Emissions lb/hr (4 (e)' In tpy (9) CO2 (h) 503,608 Ib/MMscf 180.59 790.98 N2O 0.000221b/MMBtu 0.000 0.0013 NO, 0.0681b/MMBtu 0.089 0.39 CO 0.3101b/MMBtu 0.406 1.78 SO2 0.00000Ib/MMBtu 0.000 0.00 Kiln 7.61b/MMscf 0.00 0.02 PM2.e 7.61b/MMscf 0.00 I 0.02 Pollutant Wt % of Gas (b) Emission Factor (') (Ib/MMscf) VOC Emission Rates (1) Uncontrolled Controlled CO2 (k) 0.2622 437.28 0.12 lb/hr 0.55 tpy 0.12 lb/hr 0.55 tpy Methane 0.6112 1,019.31 0.29 lb/hr 1.28 tpy 0.01 lb/hr 0.07 tpy VOC 96.4923 160,921.91 45.93 lb/hr 201.16 tpy 2.30 lb/hr 10.06 tpy Benzene 0.6840 1,140.72 0.33 lb/hr 1.426 tpy 0.016 lb/hr 0.072 tpy Toluene 0.1642 273.84 0.08 lb/hr 0.343 tpy 0.004 lb/hr 0.018 tpy Ethylbenzene 0.0021 3.50 0.00 lb/hr 0.005 tpy 0.000 lb/hr 0.001 tpy Xylenes 0.0057 9.51 0.00 lb/hr 0.012 tpy 0.000 lb/hr 0.001 tpy n -Hexane 6.1585 10,270.64 2.93 lb/hr 12.839 tpy 0.147 lb/hr 0.642 tpy 2,2,4-TMP 0.0012 2.00 0.00 lb/hr 0.003 tpy 0.000 lb/hr 0.001 tpy Notes: (a) Annual flow rate is the requested rolling -12 month throughput limit. (b) Based on the weighted average of the low pressure gas analyses (c) Emission factors are from AP -42 Tables 13.5-1 & 2 (Industrial Flares) SO, emissions based on complete conversion of H2S to SO2 (ppm H2S) / (379 scf/Ib-mole) • (1 mole 5O2/mole H2S)' (64 lb SO2/lb-mole) / (Btu/scf) = lb SO, / MMBtu N2O emission factor from 40 CFR Part 98 Table C-2 for Natural Gas. (d) Hourly Emission Rate except for PK° and CO2: lb/hr= (Emission Factor, Ib/MMBtu)' (Heat Input, MMBtu/hr) (e) CO2 lb/hr = (Emission Factor, Ib/MMscf)' (MMscf/108 scf)' (Gas Flow Rate, scf/hr) (f) lb PM 8 / hr= 7.6 (Ib/MMscf)' (scf/hr) / 1e6 (scf/MMscf) (g) Annual Emission Rate (tpy) _ (Hourly Emission Rate, lb/hr) (hr/yr) / (2,000 lb/ton) (h) This represents CO2 as a product of combustion. It is calculated using equation W-21 of 40 CFR Part 98 (i) Emission Factor (Ib/MMscf) _ (MW, lb/lb-mole) / (379 scf/Ib-mole)' (consituent weight %) / 100' 1d (j) VOC and HAP emissions: Uncontrolled Controlled (scf/hr)' (Ib/MMscf) / 10^6 = lb/hr (lb/hr) (100 - DE %) / (100) = lb/hr (lb /hr) (hr/yr) (ton/2,000 lb) = ton/yr (ton/yr) (100 - DE%) / (100) = ton/yr (k) This represents CO2 existing in the fuel gas (uncombusted) Emissions Permit/APEN Cancellation Request - Form APCD-107x, Air Pollution Control Division Stationary Sources Program All sections of this Emissions Permit/APEN Cancellation Request must be completed for any request to cancel an Emissions Permit or APEN and submitted to the Colorado Department of Public Health and Environment's Air Pollution Control Division (APCD). A cancellation request with missing information may be determined incomplete and may be returned or result in a longer cancellation processing time. Section 1 - Administrative Information Please note, specific facility information needed for this section can be found on your facility's emissions permit on the bottom left corner of each page, in the facility's emissions permit equipment description(s), or on your most recent Annual Emission Fee Invoice. AIRS ID(s): 123/9C07/023 Permit Number(s): 14WE094 Equipment Description: Owner or Operator of Permit: Facility or Equipment Address: Gas venting from two (2) vapor recovery towers during vapor recovery unit downtime. Bonanza Creek Energy Operating Company, LLC (BCEOC) North Platte K-22 Production Facility (COGCC #433629) 40.391225, -104.421929, NWNW, 5N, 22, 63W Permit Contact: Alisson Soehner Mailing Address: 410 17th Street, Suite 1400 Denver, CO 80202 Phone Number: (303) 803-1752 Email Address: asoehner@bonanzacrkcorn Date Facility or Equipment Ceased or Went Below Reporting Thresholds: 7 30 / 2020 Section 2 - Reason for Emissions Permit/APEN Cancellation ❑� The facility or equipment addressed by the permit or APEN no longer exists. ❑ The facility or equipment has been sold to another party and I do not wish to transfer the permit. i Please review the information on the following page of the APCD website before selecting this option: https:iiwww.colorado.gov/pacitrccdphelair-permitting-cancellation-exempt sources The facility or equipment has dropped below reporting thresholds. The permit was previously required solely because the emissions unit was subject to NSPS or MACT/NESHAP requirements that were adopted into Colorado Regulations (see PS Memo 14-01 for more info). This cancellation request is for (check appropriate box): ❑ Permit Only (The unit is still active. The permit will be cancelled, but the APEN will remain active because emissions are above APEN- reporting thresholds. The emissions unit is now subject to one of the general exemption letters found on the following page of the APCD website: h(C,�;,_ vw-iiLrac!. 9iy!pa _.dpne/air-perrll teig-{an ia"tion exempt y,)u, ❑ Permit Et APEN (Both the permit and the APEN will be cancelled. The unit is still active, but emissions are below APEN-reporting thresholds.) Section 3 - Owner or Operator Certification I have reviewed this cancellation request in its entirety and I hereby certify that all information contained herein is true, accurate, and complete. 08/03/2020 Signature of Legally Authorized Person (not a vendor or consultant) Date Alisson Soehner Name (please print) Environmental Engineer, Air Quality Title Send completed form to: CDPHE - Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South. Denver, CO 80246-1530 Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692.3175 or (303) 692-3148 Or visit the APCD website at: /www cptoradc.gpviRacificicdpherapcd wry COLORADO Hello