HomeMy WebLinkAbout20210061.tiffPublic Rev,e-c.)
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COLORADO
Department of Public
Health b Environment
Weld County - Clerk to the Board
1150 0 St
PO Box 758
Greeley, CO 80632
December 23, 2020
Dear Sir or Madam:
RECEIVED
JAN 0 4 2021
WELD COUNTY
COMMISSIONERS
On December 24, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for
Bonanza Creek Energy Operating Company, LLC - North Platte J -24/I-24 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 &t Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
Jared Polis, Governor I Jill Hunsaker Ryan, MPH, Executive Director
GCPLCTP) Ht_OstrqPW(314/ER/GH/GK),
OC,(3K)
Ol/o7/2l
2021-0061
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Bonanza Creek Energy Operating Company, LLC - North Platte J -24/I-24 Production Facility -
Weld County
Notice Period Begins: December 24, 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 J -24/I-24 Production Facility
Exploration Et Production Well Pad
SESW Section 24, T5N, R63, Weld County, CO
Weld County
The proposed project or activity is as follows: Added Truck Loadout (Point 020) from GP07. Added
Separator Gas Venting (Point 021).
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 12WE2994 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:
Thang Nghiem
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
Department of Public
Health 6 Environment
i
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and en
CONSTRUCTION PERMIT
Permit number:
Date issued: January 8, 2020
Issued to:
12WE2994
Issuance: 5
Bonanza Creek Energy Operating Company, LLC
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
North Platte J -24/I-24 Production Facility
123/9A5F
SESW Quadrant of Section 24, Township 5N, Range 63W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control Description
P-1 a P-2
004
Two (2) pneumatic pumps for water
transfer and heat trace circulation,
rated at 600 scf/hr each
(Sandpiper, Model G1 F, Serial
numbers 4002442 >:t 1991654).
The pneumatic pumps are controlled
by two enclosed flares. Each flare has
a minimum control efficiency of 95%.
CNDTK-02
018
Sixteen (16) 750 barrel fixed roof
storage vessels used to store
condensate
Four (4) LEED L30-0010 Enclosed
Combustors with a 98% Manufacturer
Guaranteed Control Efficiency
PWT-02
019
Two (2) 750 barrel fixed roof
storage vessels used to store
produced water
Four (4) LEED L30-0010 Enclosed
Combustors with a 98% Manufacturer
Guaranteed Control Efficiency
L-02
020
Truck Loadout
Two (2) LEED EC48 Enclosed
Combustors with a 98% Manufacturer
Guaranteed Control Efficiency
LPGFL
021
Separator Gas Venting
Point 004: This pump may be replaced with another pump in accordance with the provisions of the
Alternate Operating Scenario (AOS) in this permit.
Page 1 of 20
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COLORADO
Air Pollution Control Division
Department of Puoltc Health 6 Enwonment
Dedicated to protecting and improving the health and of
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. Points 018, 019 and 021: YOU MUST notify the Air Pollution Control Division (the Division) no
later than fifteen days of the latter of commencement of operation or issuance of this permit,
by submitting a Notice of Startup form to the Division for the equipment covered by this permit.
The Notice of Startup form may be downloaded online at
www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the
permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3,
Part B, Section III.G.1. and can result in the revocation of the permit.
2. Points 018, 019 and 021: Within one hundred and eighty days (180) of the latter of
commencement of operation or issuance of this permit, compliance with the conditions
contained in this permit must be demonstrated to the Division. It is the owner or operator's
responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance
within 180 days may result in revocation of the permit. A self certification form and guidance
on how to self -certify compliance as required by this permit may be obtained online at
www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
3. Points 018, 019 and 021: This permit must expire if the owner or operator of the source for
which this permit was issued: (i) does not commence construction/modification or operation of
this source within 18 months after either, the date of issuance of this construction permit or
the date on which such construction or activity was scheduled to commence as set forth in the
permit application associated with this permit; (ii) discontinues construction for a period of
eighteen months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
4. Points 018, 019 and 021: The operator must complete all initial compliance testing and
sampling as required in this permit and submit the results to the Division as part of the self -
certification process. (Regulation Number 3, Part B, Section III.E.)
5. Points 018, 019 and 021: The operator must retain the permit final authorization letter issued
by the Division, after completion of self -certification, with the most current construction
permit. This construction permit alone does not provide final authority for the operation of this
source.
6. Point 021: The operator must install a flow meter to monitor and record volumetric flow rate
of natural gas vented from each separator covered by this permit upon commencement of
operation.
Page 2 of 20
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COLORADO
Air Pollution Control Division
Department of PubItc Health b Enwonment
Dedicated to protecting and improving the health and en
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4. )
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
VOC
CO
P-1 Et P-2
004
6.9
2.7
Point
CNDTK-02
018
24.3
3.3
Point
PWT-02
019
0.5
--
Point.
L-02
020
4.3
--
Point
LPGFL
021
3.1
--
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to
calculate limits.
Facility -wide emissions of each individual hazardous air pollutant 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.
8. 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.
9. 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.)
Page 3 of 20
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COLORADO
Air Pollution Control Division
Department of Puolic Health b Environment
Dedicated to protecting and improving the health and en
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
P-1 Et P-2
004
Enclosed Combustor
VOC and HAP
CNDTK-02
018
Four (4) LEED L30-0010 Enclosed
Combustors with a 98% Manufacturer
Guaranteed Control Efficiency
VOC and HAP
PWT-02
019
Four (4) LEED L30-0010 Enclosed
Combustors with a 98% Manufacturer
Guaranteed Control Efficiency
VOC and HAP
L-02
020
Two (2) LEED EC48 Enclosed
Combustors with a 98% Manufacturer
Guaranteed Control Efficiency
VOC and HAP
LPGFL
021
Two (2) LEED EC48 Enclosed
Combustors with a 98% Manufacturer
Guaranteed Control Efficiency
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
10. 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
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
P-1 Et P-2
004
Natural Gas Consumed
10.5 MMSCF
CNDTK-02
018
Condensate Throughput
11,497,500 barrels
PWT-02
019
Produced Water Throughput
438,000 barrels
L-02
020
Condensate Throughput
730,000 barrels
LPGFL
021
Natural Gas Venting
1.0 MMSCF
Page 4 of 20
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COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and en
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.
11. Point 021: The owner or operator must continuously monitor and record the volumetric flow
rate of natural gas vented from the separator(s) using a flow meter. The flow meter must be
calibrated and maintained per the manufacturer's specifications and schedule. The owner or
operator must use monthly throughput records to demonstrate compliance with the process
limits contained in this permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. 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)
13. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
14. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the
source. During periods of startup, process modification, or adjustment of control equipment
visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive
minutes. Emission control devices subject to Regulation 7, Part D, Sections I.C.1.d or II.B.2.b
shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. Et 5.)
15. Point 018: This source is subject to Regulation Number 7, Part D, Section I. The operator must
comply with all applicable requirements of Part D, Section I and, specifically, must:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for condensate 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.) (State only enforceable)
16. Points 018 - 021: The combustion device covered by this permit is subject to Regulation
Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other
combustion device is used to control emissions of volatile organic compounds to comply with
Part D, Section II, it must be enclosed; have no visible emissions during normal operations, as
defined under Regulation Number 7, Part D, Section II.A.20.; and be designed so that an
observer can, by means of visual observation from the outside of the enclosed flare or
combustion device, or by other convenient means approved by the Division, determine whether
it is operating properly. This flare must be equipped with an operational auto -igniter according
to the following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
Page 5 of 20
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COLORADO
Air Pollution Control Division
Department of Public Health 6 Enwonment
Dedicated to protecting and improving the health and
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
17. Points 018 and 019: The storage tank covered by this permit is subject to the emission control
requirements in Regulation Number 7, Part D, Section II.C.1. The owner or operator must install
and operate air pollution control equipment that achieves an average hydrocarbon control
efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency
of at least 98% for hydrocarbons except where the combustion device has been authorized by
permit prior to May 1, 2014. 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.
18. Points 018 and 019: The storage tanks covered by this permit are subject to the venting
requirements of Regulation Number 7, Part D, Section II.C.2a.
19. Point 018: This source is subject to the New Source Performance Standards requirements of
Regulation Number 6, Part A, Subpart Kb, Standards of Performance for Volatile Organic Liquid
Storage Vessels for which construction, reconstruction or modification commenced after July
23, 1984, including, but not limited to, the following (Regulation Number 6, Subparts A and
Kb):
• 40 CFR, Part 60, Subpart A - General Provisions
• $60.112b - Standard for volatile organic compounds (VOC)
0 $60.112b(a) The owner or operator of each storage vessel with a....design capacity
greater than or equal to 151 m3 containing a VOL that, as stored, has a maximum true
vapor pressure equal to or greater than 5.2 kPa but less than 76.6 kPa, shall equip each
storage vessel with one of the following:
■ $60.112b(a)(3) A closed vent system and control device meeting the following
specifications:
• $60.112b(a)(3)(i) The closed vent system shall be designed to collect all
VOC vapors and gases discharged from the storage vessel and operated
with no detectable emissions as indicated by an instrument reading of
less than 500 ppm above background and visual inspections, as
determined in part 60, subpart VV, $60.485(b).
• $60.112b(a)(3)(ii) The control device shall be designed and operated to
reduce inlet VOC emissions by 95 percent or greater. If a flare is used as
the control device, it shall meet the specifications described in the
general control device requirements (S60.18) of the General Provisions.
Page 6 of 20
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!COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and e
o $60.113b - Testing and procedures
■ The owner or operator of each storage vessel as specified in $60.112b(a) shall
meet the requirements of paragraph (a), (b), or (c) of this section. The
applicable paragraph for a particular storage vessel depends on the control
equipment installed to meet the requirements of $60.112b.
■ $60.113b(c) The owner or operator of each source that is equipped with a closed
vent system and control device as required in $60.112b (a)(3) or (b)(2) (other
than a flare) is exempt from 560.8 of the General Provisions and shall meet the
following requirements.
■ $60.113b(c)(1) Submit for approval by the Administrator as an attachment to
the notification required by $60.7(a)(1) or, if the facility is exempt from
$60.7(a)(1), as an attachment to the notification required by $60.7(a)(2), an
operating plan containing the information listed [in $60.113b(c)(1)(i) and
$60.113b(c)(1)(ii)].
■ $60.113b(c)(2) Operate the closed vent system and control device and monitor
the parameters of the closed vent system and control device in accordance with
the operating plan submitted to the Administrator in accordance with paragraph
(c)(1) of this section, unless the plan was modified by the Administrator during
the review process. In this case, the modified plan applies.
o $60.115b - Reporting and recordkeeping requirements
■ $60.115b(c) After installing control equipment in accordance with $60.112b
(a)(3) or (b)(1) (closed vent system and control device other than a flare), the
owner or operator shall keep the following records.
■ $60.115b(c)(1) A copy of the operating plan.
■ $60.115b(c)(2) A record of the measured values of the parameters monitored in
accordance with $60.113b(c)(2).
o $60.116b - Monitoring of operations
■ $60.116b(a) The owner or operator shall keep copies of all records required by
this section, except for the record required by paragraph (b) of this section, for
at least 2 years. The record required by paragraph (b) of this section will be kept
for the life of the source.
■ $60.116b(b) The owner or operator of each storage vessel as specified in
$60.110b(a) shall keep readily accessible records showing the dimension of the
storage vessel and an analysis showing the capacity of the storage vessel.
■ $60.116b(g) The owner or operator of each vessel equipped with a closed vent
system and control device meeting the specification of $60.112b or with
emissions reductions equipment as specified in 40 CFR 65.42(b)(4), (b)(5), (b)(6),
or (c) is exempt from the requirements of paragraphs (c) and (d) of this section.
20. Point 020: 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
Page 7 of 20
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COLORADO
Air Pollution Control Division
Department of PubIto Health 6 Envuonment
Dedicated to protecting and improving the health and e
pollution control equipment. Compliance with Section II.C.5. must be achieved in accordance
with the following schedule: (Regulation Number 7, Part D, Section II.C.5.a.)
• Facilities constructed or modified on or after May 1, 2020, must be in compliance by
commencement of operation.
• Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021.
• Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.5.a.(i)(B) that exceed the
hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal to
5,000 barrels per year on a rolling 12 -month basis must control emissions from loadout
upon exceeding the loadout threshold.
21. Point 020: Storage tanks must operate without venting at all times during loadout. (Regulation
Number 7, Part D, Section II.C.5.a.(ii))
22. Point 020: The owner or operator must, as applicable (Regulation Number 7, Part D, Section
II.C.5.a.(iii)):
• Install and operate the vapor collection and return equipment to collect vapors during
the loadout of hydrocarbon liquids to tank compartments of outbound transport vehicles
and to route the vapors to the storage tank or air pollution control equipment.
• Include devices to prevent the release of vapor from vapor recovery hoses not in use.
• Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to
transport vehicles unless the vapor collection and return system is in use.
• Operate all recovery and disposal equipment at a back -pressure less than the pressure
relief valve setting of transport vehicles.
• The owner or operator must inspect onsite loading equipment to ensure that hoses,
couplings, and valves are maintained to prevent dripping, leaking, or other 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.
23. Point 020: The owner or operator must perform the following observations and training
(Regulation Number 7, Part D, Section II.C.5.a.(iv)):
• The owner or operator must observe loadout to confirm that all storage tanks operate
without venting when loadout operations are active. These inspections must occur at
least monthly, unless loadout occurs less frequently, then as often as loadout is
occurring,
• If observation of loadout is not feasible, the owner or operator must document the
annual loadout frequency and the reason why observation is not feasible and inspect the
facility within 24 hours after loadout to confirm that all storage tank thief hatches (or
other access point to the tank) are closed and latched.
• The owner or operator must install signage at or near the loadout control system that
indicates which loadout control method(s) is used and the appropriate and necessary
operating procedures for that system.
Page 8 of 20
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COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and et
• 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.
24. Point 020: The owner or operator must retain the records required by Regulation Number 7,
Part D, Section II.C.5.a.(v) for at least two (2) years and make such records available to the
Division upon request.
• Records of the annual facility hydrocarbon liquids loadout to transport vehicles
throughput.
• Inspections, including a description of any problems found and their resolution, required
under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log.
• Records of the infeasibility of observation of loadout.
• Records of the frequency of loadout.
• Records of the annual training program, including the date and names of persons
trained.
25. Point 020: 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))
26. Point 021: The separator covered by this permit is subject to Regulation 7, Part D, Section II.F.
On or after August 1, 2014, gas coming off a separator, produced during normal operation from
any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either
be routed to a gas gathering line or controlled from the commencement of operation by air
pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If
a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
27. 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)
OPERATING Et MAINTENANCE REQUIREMENTS
28. Upon startup of these points, the owner or operator must follow the most recent operating and
maintenance pam) 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 OitM plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
Page 9 of 20
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'COLORADO
Air Pollution Control Division
partmert of t ,Gtc Hearth b Environment
Dedicated to protecting and improving the health and et
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
29. The owner or operator must demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen -minute period during normal
operation. (Regulation Number 7, Sections XII.C, XVI1.B.2. and XVII.A.16)
30. The owner/operator must complete an initial site specific extended gas analysis ("Analysis")
within one hundred and eighty days (180) after commencement of operation or issuance of this
permit, whichever comes later, of the natural gas vented from this emissions unit in order to
verify the VOC, benzene, toluene, ethylbenzene, xylenes, n -hexane, and 2,2,4-
trimethylpentane content (weight fraction) of this emission stream. Results of the Analysis must
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 must
be submitted to the Division as part of the self -certification and must demonstrate the
emissions factors established through the Analysis are less than or equal to, the emissions
factors 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.
Periodic Testing Requirements
31. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ALTERNATE OPERATING SCENARIOS
32. Point 004: 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 shall be the same
make, model and capacity as authorized in this permit.
33. Point 004: The owner or operator shall maintain a log on -site or at a local field office to
contemporaneously record the start and stop dates of any pump replacement, the
manufacturer, model number, serial number and capacity of the replacement pump.
34. Point 004: 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
35. All previous versions of this permit are cancelled upon issuance of this permit.
36. 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:
Page 10 of 20
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COLORADO
Air Pollution Control Division
Department cf Public Health b Enwonmenl
Dedicated to protecting and improving the health and e
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 V0C or NO. per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• 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.
37. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source must not exceed the Federal program threshold until a
permit is granted. (Regulation Number 3, Parts C and D).
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:
Page 11 of 20
i
IC
COLORADO
Air Pollution Control Division
Department cf PutlIte Health & Environment
Dedicated to protecting and improving the health and en
Equipment
ID
AIRS
Point
Equipment
Description
Pollutant
Emissions - tons per year
Threshold
Current Permit
Limit
P-1 It P-2
004
Two (2) pneumatic
pumps, rated at
600 scf/hr each
VOC
50
41.7
CNDTK-02
018
Sixteen (16) 750
barrel fixed roof
condensate storage
vessels
PWT-02
019
Two (2) 750 barrel
fixed roof storage
vessels used to
store produced
water
L-02
020
Truck Loadout
LPGFL
021
Separator Gas
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.
38. Point 020: This permit replaces the following permit and/or point, which are cancelled upon
issuance of this permit.
Existing Permit
Number
Existing
Emission Point
New Emission Point
GP07
123/9A5F/020
123/9A5F/020
GENERAL TERMS AND CONDITIONS
39. 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.
40. 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
Page 12 of 20
i
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and en
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.
41. 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.
42. 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.
43. 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.
44. 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.
45. 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:
Thang Nghiem
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
October 17, 2013
Issued to Bonanza Creek Energy Operating
Page 13 of 20
i
COLORADO
Air Pollution Control Division
Department of Public Health EP Environment
Dedicated to protecting and improving the health and e
Company LLC for Points 003 - 007
Issuance 2
January 14, 2016
Modification to Point 004 to increase emissions.
Remove Points 003 and 007 from the permit
since the engines have been removed from
service and source submitted cancellation
notice.
Remove Points 005 and 006 since below APEN-
thresholds and source submitted cancellation
notice.
Adding new points 009 and 016.
Issuance 3
November 13, 2017
Issued as Final Approval.
Removed Point 016 (no longer exists) and Point
009 (below APEN thresholds).
Issuance 4
January 8, 2020
Issued to Bonanza Creek Energy Operating
Company, LLC.
Added condensate storage (Point 018) and
produced water storage (Point 019) to this
permit at a synthetic minor facility in the non -
attainment area.
Issuance 5
This Issuance
Added Truck Loadout (Point 020) from GP07.
Added Separator Gas Venting (Point 021).
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-regs
Page 14 of 20
i
COLORADO
Air Pollution Control Division
Department of Public Health b Fnnronment
Dedicated to protecting and improving the health and et
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emission Rate
(lb/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate
(lb/yr)
004
Benzene
71432
651
Yes
33
n -Hexane
110543
4,310
Yes
216
Toluene
108883
593
Yes
30
Ethylbenzene
100414
92
No
5
Xylenes
1330207
252
Yes
13
2,2,4-trimethylpentane
540841
259
Yes
13
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates
above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on
the most recent Air Pollution Emission Notice.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emission
Rate
(lbty�)
Are the
emissions
reportable?
Controlled
Emission
Rate
( b/yr)
018
Benzene
71432
2,390
Yes
120
Toluene
110543
1,669
Yes
83
Ethylbenzene
108883
176
No
9
Xylenes
100414
324
Yes
16
n -Hexane
1330207
24,117
Yes
1,206
2,2,4-trimethylpentane
540841
1,849
Yes
92
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates
above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on
the most recent Air Pollution Emission Notice.
AIRS
Point
Pollutant
CAS # .
Uncontrolled
Emission
Rat
(lb�y�)
Are the
emissions
reportable?
Controlled
Emission
Rate
( b/yr)
019
Benzene
71432
285
Yes
14
Page 15 of 20
i
COLORADO
Air Pollution Control Division
Department of Public Health.6 eninionmerit
Dedicated to protecting and improving the health and et
Toluene
110543
184
No
9
Ethylbenzene
108883
11
No
1
Xylenes
100414
43
No
2
n -Hexane
1330207
206
No
10
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates
above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on
the most recent Air Pollution Emission Notice.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emission
Rat
(lb�y�)
Are the
emissions
reportable?
Controlled
Emission
Rate
b/yr)
020
Benzene
71432
304
Yes
15
Toluene
110543
--
No
--
Ethylbenzene
108883
--
No
--
Xylenes
100414
--
No
--
n-Hexane
1330207
2,635
Yes
132
2,2,4-trimethylpentane
540841
--
No
--
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates
above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on
the most recent Air Pollution Emission Notice.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emission
Rate
(lb�yr)
Are the
emissions
reportable?
Controlled
Emission
(lb/y�)
021
Benzene
71432
353
Yes
18
Toluene
110543
261
Yes
13
Ethylbenzene
108883
16
No
1
Xylenes
100414
67
No
3
n -Hexane
1330207
3,647
Yes
182
2,2,4-trimethylpentane
540841
2
No
0
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates
above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on
the most recent Air Pollution Emission Notice.
Page 16 of 20
i
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and e
5) The emission levels contained in this permit are based on the following emission factors:
Point 004:
Pollutant
Uncontrolled
lb/MMscf
vented
Controlled
lb/MMscf
vented
Source
NOx (lb/MMBTU)
0.068
0.068
AP -42
CO (lb/MMBTU)
0.37
0.37
AP -42
VOC
26,163
1,308.2
Gas Analysis
Benzene
61.959
3.0980
Gas Analysis
n -Hexane
410.02
20.501
Gas Analysis
Toluene
56.444
2.8222
Gas Analysis
Ethylbenzene
8.7898
0.4395
Gas Analysis
Xylenes
23.956
1.1978
Gas Analysis
2,2,4-trimethylpentane
24.646
1.2323
Gas Analysis
The displacement equation can found in "EPA Emission Inventory Improvement Program
Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)."
Emission factors for CO and NOx found in AP -42 Table 13.5-1. A HHV of 1,368 BTU/scf was used
for combustion calculations.
Point 018:
CAS #
Pollutant
Uncontrolled
Emission
Factors
lb/bbl
Controlled
Emission
Factors
lb/bbl
Source
--
NOx
1.23 x 10-4
1.23 x 10-4
AP -42 Chapter 13.5
Industrial Flares
--
CO
5.62 x 10-4
5.62 x 10-4
--
VOC
8.46 x 10-2
4.23 x 10.3
ProMax v5.0 with a
sales oil stabilized
sample input
71432
, Benzene
2.08 x 10-4
1.04 x 10-5
108883
Toluene
1.45 x 10-4
7.26 x 10-6
100414
Ethylbenzene
1.53 x 10-5
7.66 x 10-'
1330207
Xylene
2.82 x 10-5
1.41 x 10-6
110543
n -Hexane
2.10 x 10-3
1.05 x 10-4
540841
2,2,4-Trimethylpentane
1.61 x 10.4
8.04 x 10-6
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
Point 019:
CAS #
Pollutant
Uncontrolled
Emission
Factors
lb/bbl
Controlled
Emission
Factors
lb/bbl
Source
--
NOx
2.60 x 10-4
2.60 x 10-4
AP -42 Chapter 13.5
Industrial Flares
--
CO
1.18 x 10-3
1.18 x 10.3
--
VOC
4.33 x 10-2
2.17 x 10.3
Page 17 of 20
i
COLORADO
Air Pollution Control Division
Department of Public Health II Environment
Dedicated to protecting and improving the health and e
CAS #
Pollutant
Uncontrolled
Emission
Factors
lb/bbl
Controlled
Emission
Factors
lb/bbl
Source
Flash Liberation
Analysis of a
Pressurized Water
Sample
71432
Benzene
6.51 x 10-4
3.26 x 10-5
108883
Toluene
4.20 x 10-4
2.10 x 10-5
100414
Ethylbenzene
2.53 x 10-5
1.27 x 10-6
1330207
Xylene
9.71 x 10-5
4.86 x 10-6
110543
n -Hexane
4.70 x 10-4
2.35 x 10-5
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
Point 020:
Pollutant
CAS #
Uncontrolled
Emission
Factors
Controlled
Emission Factors
Source
NOx
--
0.0681b/MMBtu
0.0681b/MMBtu
AP -42
CO
--
0.3101b/MMBtu
0.3101b/MMBtu
AP -42
VOC
--
0.2361b/bbl
0.01181b/bbl
State -default
Benzene
71432
0.00041 lb/bbl
0.00002051b/bbl
SSEF
Toluene
108883
N/A
N/A
N/A
Ethylbenzene
100414
N/A
N/A
N/A
Xylene
1330207
N/A
N/A
N/A
n -Hexane
110543
0.0036
0.000181b/bbl
SSEF
224 TMP
540841
N/A
N/A
N/A
Point 021:
Pollutant
CAS #
Uncontrolled
Emission Factors
Controlled
Emission Factors
Source
NOx
--
0.0681b/MMBtu
0.0681b/MMBtu
AP -42
CO
--
0.3101b/MMBtu
0.3101b/MMBtu
AP -42
VOC
--
122,6181b/MMSCF
61311b/MMSCF
ProMax
Benzene
71432
3531b/MMSCF
17.651b/MMSCF
ProMax
Page 18 of 20
i
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and en
Pollutant
CAS #
Uncontrolled
Emission Factors
Controlled
Emission Factors
Source
Toluene
108883
2611b/MMSCF
13.051b/MMSCF
ProMax
Ethylbenzene
100414
16.81b/MMSCF
0.841b/MMSCF
ProMax
Xylene
1330207
66.81b/MMSCF
3.341b/MMSCF
ProMax
n -Hexane
110543
36471b/MMSCF
182.41b/MMSCF
ProMax
s224 TMP
540841
2.1 Ib/MMSCF
0.1 Ib/MMSCF
ProMax
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 permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado _ Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC and n -Hexane
PSD
Synthetic Minor Source of: VOC
NANSR
Synthetic Minor Source of: VOC
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http: //ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
Page 19 of 20
i
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and e
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 20 of 20
Coior,ado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
For Division Use Only
Review Engineer:
Package #:
Received Date:
Review Start Date:
Thang Nghiem
431101
5j8/2020
11/1/2020
Section 01 - Facility Information
Company Name: Bonanza Creek
County AIRS ID: 223
Plant AIRS ID: 945F
Facility Name: North Platte J-24/4-2�
Physical
Address/Location:
County:
Type of Facility: Exploration & Production Well Pad
What industry segment?Oii & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? Ozone (NOx &:V-OC)
_E_ �,tsa o,. _ _ car oa s 4.
Weld County
Section 02 - Emissions Units In Permit Application
Leave Blank - For Division Use Only
AIRS Point #
(Leave blank unless APCD
has already assigned)
Emissions Source Type
Equipment Name
Emissions
Control?
Permit#
(Leave blank unless
APCD has already
assigned)
Issuance
#
Self Cert
Required?
Action
Engineering
Remarks
020
Liquid Loading
Truck Loadoui
Yes
12WE2994
Yes
Permit
Modification
021 -
Separator Venting.
Separator Gas
Yes
12WE2994
S.
Yes
Permit
Modification
Yes
Quadrant
Section
Township
Range
24
63
Section 03 - Description of Project
Bonanza Creek Energy Operating Company, LLC (BCEOC) submitted the permit modification application for the planned North Platte J-24/1-24 Production Facility (COGCC
#4290601TBD) in May, 2020. BCEOC would like to add the truck load out (L-02, AIRS Point 020) and low pressure gas flaring (LPGFL, AIRS Point 021) at the North Platte Production
Facility (COGCC #4290601TBD, AIRS ID: 123/9A5F) to this permit 12WE2994.CP4. Truck load out was previously permitted under GP07 and will now be covered under permit
12WE2994. Low pressure gas was initially sent to the sales pipeline, however BCEOC is requesting this source to be permitted to route to the ECDs onsite for control. Both of these
new points will be controlled by two new enclosed combustion devices. Net VOC permitted emissions will decrease by 2.6 tpy, with. negligible changes in other pollutants. New
references for Reg 7 were also updated.
Sections 04, OS & 06 - For Division Use Only
Section 04 - Public Comment Requirements
Is Public Comment Required? Fes
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requiremeni
Was a quantitative modeling analysis required? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes, indicate programs and which pollutants: 502 NOx CO
Prevention of Significant Deterioration (PSD) ❑ ❑ ❑
Title V Operating Permits (OP) ❑ ❑ ❑
Non -Attainment New Source Review (NANSR) L
Is this stationary source a major source? No
If yes, indicate programs and which pollutants: SO2 NOx CO
Prevention of Significant Deterioration (HD) Li I)_
Title V Operating Permits (OP) L ( L❑
Non -Attainment New Source Review (NANSR) ❑
VOC
❑
❑
IA
VOC
;I
LJ
❑
PM2.5
❑
❑
PM2.5
J
J
PM10 TSP
❑
❑ ❑
PM10 TSP
? )J
HAPs
❑
HAPs
',_J
Flydrocarbon, Loadout Emissions inventory
Section 01 -Administrative Information
'Facility AIRs ID:
123
County
Plant
Point
Section 02- Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Is this loadout controlled?
Requested Overall VOC & HAP Control Efficiency
Section 03. Processing Rate Information for Emissions Estimates
Primary Emissions- Hydrocarbon Loadout
Actual Volume Loaded =.
'Requested Permit Umit Throughput=
Potential to Emit (PTE) Volume Loaded =
Secondary Emissions - Combustion Device's)
Heat content of waste gas =
Gas to Oil Ratio
Actual Volume of waste gas emitted per year =
Requested Volume of waste gas emitted per year =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
,000: Barrels (bbl) per year
730,000. Barrels (bbl) per year
730,000, Barrels (bbl) per year
3194 Btu/scf
;scf/bbl
scf/year
100-525 scf/year
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
N/A
Requested Monthly Throughput= 52000 Barrels(661) per month
MMBTU per year
3,10S MMBTU per year
3.2C9 MMBTU per year
Control Device
Pilot Fuel Use Rate:
Pilot Fuel Gas Heating Value:
cfh
to/scf
0.0 MMscf/yr
9.0 MMBTU/yr
Section 04- Emissions Factors & Methodologies
Does the company use the state default emissions factors to estimate emissions?
Does the hydrocarbon liquid loading operation utilize submerged fill?
default emissions factors maybe used to estimate em ssiorm
EIMEMEIEEMINIM
Pollutant
Control Device
Pollutant
Pilot Light Emissions
Pollutant
Hydrocarbon Loadout
(lb/bbl)
ph/bbl)
(Volume Loaded)
(Volume Loaded)
Uncontrolled
(Ib/MMBtu)
Uncontrolled
(lb/bbl)
(waste heat combusted)
Volume Loaded)
Uncontrolled
(Ib/MMBtu)
Uncontrolled
(Ib/MMscf)
(Pilot Gas
Throughput)
(Waste Heat Combusted)
Emission Factor Source
Emission Factor Source
Emission Factor Source
1oft
H:\CP\Bonanaza Creek \Bonanza Creek 12WE2994 E2994.CP5.PA DRAFT
Hydrocarbon lioadoiiit Emissions inventory
Section OS - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tans/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
,._._
q __
0 q
0.00
.,-:,_
0
_. __,
„'.00
0.94
C r
0
.._._
..
0.00
9.00
4.00'
...
�
-..
5.9.14
4X31
SE" -__d
�-
,..Ev
O.GO
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 TMP
_. _
_._
3
20)5
p
_
:_..
131
_1.51
.,
0
.:
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
___rc_ _, tres ,arid4
Regulation 7 Part D Section II.C.5.
(See regulatory applicability worksheet for detailed analysis)
7e:roca b rt -:m es x,a nut or vu. s un - ._ta-deu la tied 7 Part It _ceo s.C.9,
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
Section 08 - Technical Analysis Notes
Section 09 - SCC Coding and Emissions Factors (For Inventory Use Only)
AIRS Point #
020
Process #
01
SCC Code
4.03,90i -32 Crude OP: Sub --merged Land _ .. ..5.
Uncontrolled
Emissions -
Pollutant Factor Control% Units
PM10 0.00 _ lb/1,000 gallons transferred
PM2.5 y.__ _ ,. lb/1,000 gallons transferred
SOx 5000 lb/1,000 gallons transferred
NOx Oq lb/1,000 gallons transferred
VOC ..c 95 lb/1,000 gallons transferred
CO ,lb/1,000 gallons transferred
A Benzene ,_�_ lb/1,000 gallons transferred
Toluene -.vt g; lb/1,000 gallons transferred
Ethylbenzene 5.917 lb/1,000 gallons transferred
Xylene ..._u _v lb/1,000 gallons transferred
n -Hexane _..._ Ih/1,000 gallons transferred
224 TMP _3119 __ lb/1,000 gallons transferred
2 of 2 MCP\Bonanaza Creek \Bonanza Creek 12W E2994\12W E2994.CP5.PA DRAFT
Hydrocarbon Loadout Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions and throughput.
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.0?
3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
'You have indicated that source it in they Non-Atta€nntaW,, Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.07
3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
'Source requires a permit
Colorado Regulation 7 Part D Section II.C.S.
1. Is this condensate storage tank hydrocarbon liquids loadout located at a well production facility, natural gas compressor station or natural gas processing plant?
2. Does the facility have a throughput of hydrocarbon liquids loadout to transport vehicles greater than or equal to 5,000 barrels?
Yes
IThe hydrocarbon ilquids kledeo➢Jt source 8""+subject to fi@ gdYiaton N.,,rt D ^ri^cbpna H,C.5
Section II.C.5.a.(I) - Compliance Schedule
Section II.C.5.a.(ii) - Operation without Venting
Section II.C.5.a.(iii) - Loadout Equipment Operation and Maintenance
Section II.C.5.a.(Iv) - Loadout observations and Operator Training
Section II.C.5.a.(v) - Records
Section II.C.5.a.(vi) - Requirements for Air Pollution Control Equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act, its
implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may,"
"should," and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as `must" and "required" are intended to describe controlling requirements under the
terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
Go to next que:
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Source is subjel
Separator Venting Emissions inventory
Section 01- Administrative Information
.'Facility AIRS ID:
County
RA5F
Plant
Point
Section 02- Equipment Description Details
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
Actual Throughput fi
t MMscf per year
Upon startup of point, not 180 days.
Requested Permit Limit Throughput —AN,, ,a -r .S#. MMscf per year Requested Monthly Throughput= •.J. MMscf per month
Potential to Emit (PTE) Throughput=
1.D MMscf per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL
liquids throughput:
to/scf
Control Device
Pilot Fuel Use Rate:
Pilot Fuel Gas Heating Value:
a_C MMscf/yr
Section 04 - Emissions Factors & Methodologies
Description
Weight. °b
Helium
G
CO2
N2
ti
methane
ethane
?:f=
propane
I:5
isobutane
z:2
n -butane
isopentane
.. Ja
n -pentane
5 5
ryclopentane
n -Hexane
-
cyclohexane
Other hexanes
heptanes
methylcyclohexane
224-TMP _
Benzene
Toluene
Ethylbenzene
Xylenes
C8+ Heavies
Total
VOC Wt %
Ib/Ib-mol
Displacement Equation
Ex=Q*MW*Xx/C
i
1 of 3 H:\CP\Bonanaza Creek \Bonanza Creek -12WE2994\12WE2994.CPS.PA' DRAFT
Vent
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
D.3
0,0
D=C
U.R
v...
6.0
D
0.0
0-0
0,0
0.0
9,1
_ _
0.1
17
_._
'635
.._...
3.z
521
's.5
15
035
0.5
0.5
73
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
355
_,,,
13
23
260
1661
132
3543
133
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7, Part D, Section ILB, F
Regulation 7, Part D, Section II.B.2.e
(See regulatory applicability worksheet for detailed analysis)
0rionPar- Di Section _,75.?. F
2 of 3 HACP\Bonanaza Creek \Bonanza Creek 12WE2994\12WE2994.CPS.PA DRAFT
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
1
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 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
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
i 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? Yes
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 ,
I_
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 t �
You have indicated above that the meri'ored process oa-amete is ratura gas vented The folio ring questions do not require an ansder
Section 08 Technical Analysis Notes _
I,This is age permittedffacihty sl s not a traditional production facility The facility will only handle some "dead," oil from nearby central production facdbes, that s sent over is pipelineito this facility The oil is sent back through a heater
treater primarily to breafSwater emuisio� before stored onsrte and sold at a nearbytermmal ifhe process was modeled with the ongmal application that resulted m rssuance 3; and no predicted flash Was shown m the separato?or m the Vi
tanks (Just W&B emissions) The` source do not think there will be`any flash hithe Heater tre'atei but wantedto permit a nominal 100 MMscf/yi-to be safe to `start A gas`sampfe with the Highest VOC content from a VRT ga`ssample (from a
ti H t < ss_w p.9-,Y,+� ,t o� r o�
" separatefacilijy) was used to esLnSete emssions As a result no good eosin oil ratio`data was available and actual aolume of erasie gas emitted per year s also not available � �' ..i.,.'4'— -sr ` ,.' _.
,a` .0 �rf`. v -a t ice' t '�' a `k '�4, `- - !' S��ir� �' P ,. rl✓P i} e1 ,f r d,
S �' ,1P; C c 'a.. y ? `'r�-1"lb y rs �'s _ a g P r s
d'? c t ,_r a <a , ?. _ ,'s,, ' as_ ✓"�sa _s' ,. r %:r ' �i _ y -
AIRS Point q
021
Process tf SCC Code
01 S 10 001 60 Flares
Section 09 SCC Coding and Emissions Factors (For Inventory Use Only)
Pollutant Uncontrolled Emissions Factor Control % Units
PM10 , 90 0 lb/MP. SCF
PM25 00 0 to/MMSCF
50x 0 0 0 IlagvIM5CF
NOx 2C09 C Ibirmr1SCF
VOC - 1229166 ,- 95 Ibr MMSCF
CO 9151 0 Ib/MMSCF
Benzene 356 0 95 ib/MMSC'
Toluene 2602 95 Ib/ivIMSCF
Ethylbenzene 154 95 Ib/fvtNKO
Xylene 671 - 95 ib/VIMSCF
n Hexane 36426 95 Ib/MMSCF
224 TMP 22 95 ib, VAi5CF
J
3 of 3 _ H \CP\Bonanaza Creek \Bonanza Creek 12WE2994\12WE2994 CP5 PA DRAFT
Separator Venting Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
,„s Jur.
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
Colorado Regulation 7, Part D, Section II
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
Section II.B.2 — General Provisions for Air Pollution Control Equipment Used to Comply with Section II
Section II.F - Control of emissions from well production facilities
Alternative Emissions Control (Optional Section)
a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed?
Section II.B.2.e —Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control
Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts
circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the et
any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regular
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
interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the
Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
�4
May 7, 2020
Stefanie Rucker
Colorado Department of Public Health and Environment
Air Pollution Control Division, APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Bonnnzn
CREEK
410 17th Street, Suite 1400
Denver, CO 80202
(720) 440-6100 phone
(720) 305-0802 fax
RE: Permit Modifications — TLO and LPGFL
North Platte J -24/I-24 Production Facility (COGCC #429060/TBD, AIRS ID: 123/9A5F)
Bonanza Creek Energy Operating Company, LLC
Weld County, CO
Ms. Rucker,
Bonanza Creek Energy Operating Company, LLC (BCEOC) is pleased to submit the attached permit
modification application for the planned North Platte J -24/I-24 Production Facility (COGCC #429060/TBD).
APENs and supporting documentation for the truck loadout (L-02, AIRS Point 020) and low pressure gas
flaring (LPGFL, AIRS Point TBD) at the North Platte Production Facility (COGCC #429060M3D, AIRS ID:
123/9A5F). Truck loadout was previously permitted under GP07 and will now be covered under permit
12WE2994. Low Pressure gas was initially sent to the sales pipeline, however BCEOC is requesting this
source now be permitted to route to the ECDs onsite for control.
In addition to the APENs, emissions calculations, and all other required documentation, a check covering
two (2) APENs filing fees totaling $382.26 is included herein.
If you need additional information regarding this modification application, please contact me at (303) 803-
1752 or via email at asoehner@bonanzacrk.com.
Sincerely,
Alisson Soehner
Environmental Engineer, Air Quality
Attachments: As stated
cc: File
(bitrOklZ£ UFFri'£
410 17' Street. Sum 1400
Denver_ CO M12117
Office !'?Ill 440-6100
Bonanza Creek Energy Operating Company, LLC. - North Platte J-24/1.24 Production Facility (COGCC 442906000000Q
VOC Emissions from 1-24 Truck Loading (AP -42 Chapter 5.2 (1/95)]
Site
Product
Loading Mode
Sales
Saturation
Factor
(S) (')
True Vapor
Pressure (P)
[psia]
Molecular
Weight (M)
[Ib/Ib-mol]
Bulk Temp,
(T) [F]
Vapor VOC
Content (C)
[wt %]
Uncontrolled
Loading Loss
(LL) (b)
[1b/bbl]
Uncontrolled
VOC Emissions
Collection
Efficiency (`)
(%]
Control
Efficiency
t/4
Controlled
VOC
Emissions
North.Piatte J -24/I-24
Condensate
Submerged loading:
dedicated vapor balance
service
730,000 bbl/year
1.0
N/A
55.58
N/A
100.00%
0.236
86.14 tpy
100.0%
95.0%
4.31 tpy
(a) Source. AP -42 Table 5.2-1 (155)
(h) Equation 1 for loading losses. (C) • (12.46) • (SPM ( T) • W = 4
Mere:
=loading losses, ibs/100D gal of liquid loaded
b = saturation factor
P = true vapor pressure of liquid loaded (psia) based on sales oil composition and Raouk's Law. The true vapor for each constituent is based on Ant
M = Molecular Weight of Vapors (lb/lb-mole) based on vapor composition.
T = temperature of bulk squids leaded "R ("F = 460) from EPA TANKS Meteorological Database for Denver, CO
(c) Based on all tanker trucks having and the collection etheciencies in AP 42 Chapter 5.2, page 5.2.6
AP -42 Chapter 5.2, Table 5.2-1 (1/95)
Submerged loading of a dean cargo tank
0.5
Submerged loading: dedicated normal service (default)
0.6
Submerged loading: dedicated vapor balance service
1.0
Splash loading of a dean cargo tank
1.45
Splash loading: dedicated normal service
1.45
Splash loading. dedicated vapor balance service
1
Marine vessels Submerged loading. ships
0.2
Submerged loading: barges
0.5
Vapor Methane
Content (C)
[wt %1
Uncontrolled
Loading Loss
(LL) lb)
[lb/1,000-gal]
Uncontrolled
Methane
Emissions
Collection
Efficiency 4)
Loki
Control
Efficiency
l%)
Controlled
Methane
Emissions
NA
NA
N/A
N/A
N/A
N/A
HAP
Wt. % of
THC j4)
Loading Loss
lb/bbl
Uncontrolled HAP Emissions (e)
Controlled HAP Emissions (e)
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
2,2,4-Trimethylpentane
0.1763%
N/A
N/A
N/A
1.5297%
N/A
_ 0.0004
N/A
N/A
N/A
0.0036
N/A
303.68 lb/yr
N/A
N/A
N/A
0.15 tpy
N/A
N/A
N/A
15_18 lb/yr _
N/A
N/A
N/A
131.77 lb/yr
N/A
_.. 0.01 tpy
N/A
N/A
N/A
0.07-tpy
N/A
2,635.30lb/yr
WA
1.32 tpy
N/A
Total
2,938,98 Ib/yr
1.47 tpy
146.95 lb/yr
0.07 tpy
(d) Calculated based on sales oil composition and Equation 1.22 of Chapter 7.1 of AP 42
(e) HAP Emissions, tpy = WOG Emissions. tpy) • (HAP Wt. % of THC)
Bonanza Creek Energy Operating Company, LLC. - North Platte J -24/I-24 Production Facility (COGCC #429060/)0OOO()
Vapor Combustion Unit (VCU) Emission Calculations for Truck Loadout
Emission Source: Truck Loadout
Source Type: VCU
Heat Input: 0.43 MMBtu/hr
Tank Vent Gas Flowrate: 134.1 scf/hr
Tank Vent Gas Flowrate: 1.17 MMscf/yr
Estimated HHV: 3,194 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
Ibihr (°)• (`)
tpy (4)
COP)
139.00 Ib/MMBtu
59.54 '
260.77
N2O
0.00022Ib/MMBtu
0.00 1
0.00
NO„
0.0681b/MMBtu
0.03
0.13
CO
0.3101b/MMBtu
0.13
0.58
SO2
0.00018Ib/MMBtu
0.0001 I
0.0003
PMlo
40.0 u9 /1
0.004
0.0155
PM2_5
40.0 u9 / i
0.004
0.0155
Notes:
(a) Emission factors are from AP -42 Tables 13.5-1 8 2 (Industrial Flares)
40 pg / L is for lightly smoking flare (this is conservative as this unit is smokeless in design).
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 PMio = (Emission Factor, Ib/MMBtu) • (Heat Input. MMBtu/hr)
(c) lb PM10 / hr = (scf CH4/hr) (10.6 scf E/scf CH4) (0.0283 m'/scf E) (40 p PM,a/L E) (1000 Um') (g/106 pg) (lb/453.59 g) / (hr/yr)
(d) Annual Emission Rate (tpy) _ (Hourly Emission Rate, Ib/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
Bonanza Creek Energy Operating Company, LLC. - North Platte J -24/I-24 Production Facility (CO(
High/Low Pressure Separator Emission Calculations
Source Type:
High/Low Pressure Separator 1
Heat Input:
0.34 MMBtu/hr
Average Hourly Flowrate (a):
114 scf/hr
Total Annual Flowrate:
1.0 MMscf/yr
Estimated HHV (b):
2,955 Btu/scf
Combustor VOC Destruction Efficiency:
95%
Molecular Weight (b):
51.9 Ib/Ib-mol
H2S Content of Fuel (b):
0.0 ppm H2S
Time Separator(s) Vent to Enclosed Flare:
8,760 hr/yr
Pollutant
Emission
Factors lc)
Emissions
b/hr (d)' (e). (n
tpy (e)
CO2 (h)
N2O
NO),
CO
SO2
PM10
PM2.5
0 Ib/MMscf
0.00022 Ib/MMBtu
0.068 Ib/MMBtu
0.370 Ib/M M Btu
0.00000 Ib/MMBtu
40.0 pg / L
40.0 pg / L
0.00
0.000
0.02
0.00
0.0003
0.10
0.12 j 0,55
0.0_0 0.00
0.00 0.01
0.00 0.01
Pollutant
Wt % of Gas (b)
Emission
Factor (i)
(1b/MMscf)
VOC Emission
Rates (I)
Controlled
Uncontrolled
CO2 (k)
0.5920
810.8
0.09 lb/hr
0,41 tpy
0.09 lb/hr
0.41 tpy
Methane
1.2852
1,760.2
0.20 lb/hr
0.88 tpy
0.01 lb/hr
0.04 tpy
VOC_
89.5276
122,617.8
14.00 lb/hr
61.31 tpy
0.70 lb/hr
3.07 tpy
Benzene
0.2578
353.1
0.040 lb/hr
0.177 tpy
0.002 lb/hr
0.009 tpy
Toluene
0.1906
261.1
0.030 lb/hr
0.131 tpy
0.001 lb/hr •
0.007 tpy
Ethylbenzene
0.0122
16.8
0.002 lb/hr
0.008 tpy
0.000 lb/hr
0.000 tpy
Xylenes
0.0488
66.8
0.008 lb/hr
0.033 tpy
0.000 lb/hr
0.002 tpy
n -Hexane_
2,2,4-TMP
-
2.6_626
0.0016
3,646.7
2.1
0_.41_6_Ib/_hr
0.000 lb/hr
_ 1.823 tpy
I 0.001 tpy
_ 0.0_21 lb/hr
0.000 lb/hr
0.091 tpy
0.000 tpy
Notes:
(a) Hourly flow rate is based on ProMaxe simulation plus a 20°i safety factor
(b) Based on the weighted average of low pressure gas analysis
(c) Emission factors are from AP -42 Tables 13.5-1 & 2 (Industrial Flares)
40 pg / L is for lightly smoking flare (this is conservative as this unit is smokeless in design).
SO2 emissions based on complete conversion of H2S to SO2
(ppm H2S) / (379 scf/lb-mole) ` (1 mole SO2/mole H2S) ' (64 lb SO2/lb-mole) / (Btu/scf) = lb SO2 / MMBtu
N2O emission factor from 40 CFR Part 98 Table C-2 for Natural Gas.
(d) Hourly Emission Rate except for PM,o and CO2: lb/hr = (Emission Factor. Ib/MMBtu) ' (Heat Input. MMBtu/hr)
(e) CO2 lb/hr = (Emission Factor, Ib/MMsef) ' (MMscfi106 scf) . (Gas Flow Rate, scf/hr)
(f) lb PM, / hr = (MMscf CH4) (10.6 scf E/scf CH4) (0.0283 m'/scf E) (40 p PM,o/L E) (1000 Wm') (g/106 Ng) (lb/453,59 g) / (hr/yr)
(g) Annual Emission Rate (tpy) _ (Hourly Emission Rate, lb/hr) ' (hr/yr) / (2,000 lb/ton)
(h) This represents CO2 as a product of combustion. tt is calculated using equation W-21 of 40 CFR Part 98
(i) Emission Factor (Ib/MMsef) _ (MW. Ibflb-mole) / (379 scf/Ib-mole) ' (consituent weight %) / 100 ' 106
p) VOC and HAP emissions:
Uncontrolled Controlled
Gas Analysis Number:
Analysis 1
Weighted Average of Low Pressure Gas
Well Name:
Source:
Sample Date:
Laboratory:
North Platte K-22
VRT Gas
Sample Pressure (psig):
Sample Temperature ("F):
CO, from
Component MWi
Mol •/.
Component MW
(Mol %)
Wt
(Wt %)
Atoms
Combustion
ibfibmol Gas
Ib/MMscf
Helium 4
0
Helium 4
0.0000
0.0000
0,0000
D
0
Hydrogen 2.02
0
Hydrogen 2.02
0.0000
0.0000
0.0000
0
0
Carbon Dioxide 44.01
0.6982
Carbon Dioxide 44.01
0.6982
0.3073
0.5920
0
0
Nitrogen 28.01
0.9934
Nitrogen 28.01
0.9934
0.2782
0.5360
0
0
Methane 16.041
4.1588
Methane 16.041
4.1588
0.6671
1.2852
1
4,829
Ethane 30.063
13.5145
Ethane 30.063
13.5145
4.0629
7.8270
2
31,386
Propane 44.092
31.9558
Propane 44.092
31.9558
14.0899
27.1440
3
111,323
Isobutane 58.118
6.4587
Isobutane 58.118
6.4587
3.7537
7.2314
4
30,000
n -Butane 58.118
21.7974
n -Butane 58.118
21.7974
12.6682
24.4050
4
101,246
Isopentane 72.114
5,3177
Isopentane 72.114
5.3177
3.8348
7.3876
5
30.875
n -Pentane 72.114
6.9087
n -Pentane 72.114
6.9087+
4.9822
9.5980
5
40,113
Cydopentane 70.13
0.4421
Cydopentane 70.13
0.4421
0.3100
0.5973
5
2,567
n -Hexane 86.17
1.6039
n -Hexane 86.17
1.6039
1.3821
2.6626
6
11,175
Cydohexane 84.16
0.3611
Cydohexane 84.16
0.3611
0.3039
0.5855
6
2,516
Other Hexanes 86.18
2.5190
Other Hexanes 86.18
2.5190
2.1709
4.1822
6
17,551
Heplanes 100.21
1.7595
Heptanes 100.21
1.7595
1.7632
3.3967
7
14.302
Methycydohexane 98.19
0.2812
Methycyclohexane 98.19
0.2812
0.2761
0.5320
7
2,286
2,2,4-TMP 114.23
0.0007
2,2,4-TMP 114.23
0.0007
0.0008
0,0016
8
7
Benzene 78.12
0.1713
Benzene 78.12
0.1713
0.1338
0.2578
6
1,193
Toluene 92.15
0.1074
Toluene 92.15
0.1074
0.0990
0.1906
7
873
Ethylbenzene 106.17
0.0060
Ethylbenzene 106.17
0.0060
0.0064
0.0122
8
56
Xylenes (Total) 106.17
0.0238
Xylenes (Total) 108.17
0.0238
0.0253
0.0488
8
221
Octanes 114.23
0.3245
Octanes 114.23
0.3245
0.3707
0.7141
8
3,014
Nonanes 128.20
0.0801
Nonanes 128.20
0.0801
0.1027
0.1978
9
837
Decanes 142.29
0.1395
Decanes 142.29
0.1395
0.1986
0.3825
10
1,620
Oxygen/Argon 32.00
0.3767
Oxygen/Argon 32.00 0.3767
0.1205
0.2322
0
0
Water 18.01
0.0000
Total
100.38
Total
99.62
51.91
99.19
405,531
Total Hydrocarbon (HC)
97.93
Total Hydrocarbon (HC)
97.9317
98.6398
Total VOC (C3+)
80.26
Total VOC (C3+)
80.2584
89.5276
Total HAP
1.91
Total HAP
1.9131
3.1735
H2S Concentration (ppm)
H2S Concentration (ppm)
0.00
Relative Density
Total MW (lb/lb-mole)
51.91
Total MW (lb/lb-mole)
51.91
Higher Heating Value (Btu/scf)
2955.44
Total HHV (Btu/scf)
2955.44
Lower Heating Value (Btu/scf)
Low Pressure Gas (MMscf/yr)
Associated with this
analysis (%)
1.00
100%
Alliance
SOURCE TESTING
EXTENDED GAS ANALYSIS
5530 Marshall Street
Arvada, Colorado 80002
Phone: 303-420-5949
Fax: 303-420-5920
SAMPLE DATA
PROJECT NO OG-2019-0170 SAMPLE ID Gas
COMPANY NAME Bonanza Creek ANALYSIS DATE ...................... 9/11/2019
SITE North Platte K-22 SAMPLE DATE 9/5/2019
UNIT ID VRT CYLINDER NO TGV-09
SAMPLED BY AJM LAB ANALYST CLB
FIELD DATA
SAMPLE PRESSURE 5.0 psig SAMPLE TEMP 90 F
AMBIENT PRESSURE 12.5 psi AMBIENT TEMP 100 F
COMMENTS: H2S= 0.0 ppm
`ASTM Method D4810 Length of Stain
LABORATORY DATA
COMPONENT MOLE %
HYDROGEN SULFIDE 0.0000 0.0000 0.0000
CARBON DIOXIDE 0.6982 0.5921 0.1218
NITROGEN 0.9934 0.5362 0.1117
METHANE 4.1588 1.2856 0.7208
ETHANE 13.5145 7.8301 3.6949
PROPANE 31.9558 27.1515 9.0004
ISOBUTANE 6.4587 7.2333 2.1607
N -BUTANE 21.7974 24.4115 7.0253
ISOPENTANE 5.3177 7.3926 1.9882
N -PENTANE 6.9087 9.6045 2.5602
CYCLOPENTANE 0.4421 0.5974 0.1339
N -HEXANE 1.6039 2.6632 0.6743
CYCLOHEXANE 0.3611 0.5856 0.1256
OTHER HEXANES 2.5190 4.1584 1.0242
HEPTANES 1.7595 3.3919 0.8233
METHYLCYCLOHEXANE 0.2812 0.5320 0.1155
2,2,4 TRIMETHYLPENTANE 0.0007 0.0016 0.0004
BENZENE 0.1713 0.2578 0.0490
TOLUENE 0.1074 0.1907 0.0367
ETHYLBENZENE 0.0060 0.0122 0.0024
XYLENES 0.0238 0.0488 0.0094
OCTANES 0.3245 0.7109 0.1656
NONANES 0.0801 0.1974 0.0456
DECANES 0.1395 0.3824 0.0874
SUBTOTAL 99.6233
OXYGEN/ARGON 0.3767
WT% GPM
99.7678 30.6774
0.2322 0.0342
TOTAL 100.00
100.00 30.71
BTU Q
MOLECULAR WEIGHT 51.8981 NET DRY REAL 2662.4593 /scf
RELATIVE DENSITY (AIR=1) 1.7919
COMPRESSIBILITY FACTOR 0.9757 GROSS DRY REAL 2955.4381 /scf
GROSS WET REAL 2901.3789 /scf
ANALYTICAL PROCEDURES TAKEN FROM GPA 228695
Form APCD-101
COLORADO
Department of Public
Health & Environment
Company Contact Information Form
Ver. September 10, ?008
Company Name: Bonanza Creek Energy Operating Company, LLC
Source Name: North Platte J -24/I-24 Production Facility (COGCC #429060)
Permit
Contact':
Alisson Soehner
Address:
410 17th Street, Suite 1400
Street
Denver
CO
80202
City
State
Zip
Phone Number:
(303) 803-1752
Fax Number:
(720) 305-0804
E-mail:
asoehner@bonanzacrk.com
Billing Contact:
(Permit Fees)j
Alisson Soehner
Address:
410 17th Street, Suite 1400
Street
Denver
CO
80202
City
State
Zip
Phone Number:
(303) 803-1752
Fax Number:
(720) 305-0804
E-mail:
asoehner@bonanzacrk.com
Compliance
Contact':
Matt Cannizzaro
Address:
410 17th Street, Suite 1400
Street
Denver
CO
80202
City
State
Zip
Phone Number:
(303) 803-1752
Fax Number:
(720) 305-0804
E-mail:
mcannizzaro@bonanzacrk.com
Billing Contact:
(Annual Fees)'
Alisson Soehner
Address:
410 17th Street, Suite 1400
Street
Denver
CO
80202
City
State
Zip
Phone Number:
(303) 803-1752
Fax Number:
(720) 305-0804
E-mail:
asoehner@bonanzacrk.com
Check how would you like to receive your permit fee invoice?
Mail:
E-mail: Q
Fax: n
Footnotes:
' The permit contact should be the point of contact for technical information contained in the permit application.
This may be a company representative or a consultant.
The compliance contact should be the point of contact for discussing inspection and compliance at the permitted
facility.
' The billing contact (Permit fees) should be the point of contact that should receive the invoice for fees
associated with processing the permit application & issuing the permit. (Reg. 3, Part A, Section VI.B)
a The billing contact (Annual fees) should be the point of contact that should receive the invoices issued on an
annual basis for fees associated with actual emissions reported on APENs for the facility. (Reg. 3, Part A,
Section VI.C)
Page I of I AP_Form-APC D-1 0 1 -Company -Contact -Information (2) doc
Form APCD-102
Company, Name: &manta Creek Energv Operating Pompom, LLC
Source Name: North Platte 1-2411.24 Production Pad tCOO(Ta A291MMXXXXX)
Source AIRS ID: I2379A'St
Colorado Department of Public Ilealth and Environment
Air Pollution Control Division
Facility Wide Emissions Inventory Form
Ver April. 2nl5
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PIIIIImItC1:
I This form should be completed to include both existing sources and all proposed urn or modifications to existing emisnons ,SOUIces
2. If the emisslms source a new then enter "proposed" under the Perms No and AIRS II) data columns
3. HAP abbreviations includc-
BZ = Bl:vom 224 -IMP = 2.2 4-Trimcth5lpcntane
Tul = Toluene Aceull = AcetaldeMdc
EB = Ethylbervene - Acnl Acrolem
Xcl - Xs lenc miles - mnesane
HERO =' Ponnnideh>de Meth " Methanol
4 APEN Exempt/Insignificant SIWtt'eS should be included when warranted.
Company Name
514/2020
Page 1 of 1
�4
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CREEK
Process Description
North Platte J -24/I-24 Oil & Gas Production Facility
North Platte J-24 Production Facility (COGCC #429060) is an existing oil and gas production facility
located within the eight -hour (8 -hr) Ozone Control Area of Weld County. The facility produces both oil
and natural gas from six (6) wells: North Platte 24-21-24HZ, North Platte J-F-24HZ, North Platte O-K-
24HC, North Platte O-K-24HNB, North Platte E-A-24HNC and North Platte E-A-24HNA. North Platte I-24
(COGCC #TBD) is a planned oil production facility and the subject of this permit application. The facility
will be co -located with North Platte J-24, but the equipment and processes of the J-24 and I-24 facilities
will remain separate. The process description and process flow diagram describes these facilities
independently for clarity.
North Platte J-24 Production Facility
As of October, 2014, the facility sends produced condensate to the State North Platte 42-26 Central
Production Facility (CPF). The facility currently has the following equipment onsite:
• One (1) 300 bbl Condensate Tank, currently not in use;
• Four (4) 400 bbl Produced Water storage tanks;
• One Concrete Produced Water Vault (1 @ 60 bbl capacity);
• Hydrocarbon Liquids Truck Loading Operation;
• Two (2) Cimarron Model 48HVECD 48"x25' Enclosed Combustors;
• Fugitive Equipment Leaks;
• Two (2) Sandpiper G1 F Pneumatic Pump used for water transfer and heat trace;
• Six (6) Separators (0.75 MMBtu/hr capacity).
Gas and oil produced from the wells are processed through heated separators, where oil and water are
separated. Oil from the separators is piped to the State North Platte 42-26 CPF. The overhead gas from
the heated separators is sent to a gathering pipeline.
The 400 -bbl water tanks receive produced water from the separators. The 300 -bbl tank on site is currently
not in use, and was previously used to store compressor liquids.
There is one (1) partially buried 60 -bbl concrete water vault that is uncontrolled. This vault typically
receives produced water by gravity feed from the facility drains. The water vault is used as a drain and
the water is typically transferred back to the produced water tanks via pump once the draining process is
complete. These vaults may also see water drained from the knockout vessels on the vapor lines to the
ECDs as well as some drips from the slobber boxes that collect any oil/water spray from around the tank
thief hatches.
Flashing, working and breathing loss vapors from the 400 bbl water tanks are routed to the enclosed
combustors. The enclosed combustors have a vendor guaranteed destruction efficiency of 98% or
higher.
One gas pneumatic pump is used as a water transfer pump, the other is used as heat trace. The motive
gas used for the pump is controlled by the combustors.
�P
Boma
CREEK
The heated separators, fugitives, truck loading process, pneumatic devices, water tanks and water vault
are APEN exempt emission sources, having less than 2 tons per year of any single criteria pollutant and
less than 1 tpy of VOC and NO. (the facility is located within the nonattainment 8 -hour Ozone Control
Area).
North Platte I-24 Facility
The planned North Platte I-24 Facility will handle condensate pumped from the Antelope 13-21, State
Antelope O-1, State Pronghorn 41-32 and State North Platte 42-26 CPF's.
The following equipment is planned to be on site;
• Sixteen (16) 750 bbl Condensate Tanks;
• Two (2) 750 bbl Produced Water Tanks;
• Hydrocarbon Liquids Truck Loading Operation;
• Produced Water Truck Loading Operation;
• Three (3) Recycle/Charge Pumps
• Four (4) Pump/LACT Buildings
• Two (2) LEED EC 48 48" Enclosed Combustors;
• Fugitive Equipment Leaks;
• One (1) Heated Separators (1.0 MMBtu/hr Capacity)
• Two (2) Line Heaters (2.5 MMBtu/hr Capacity)
• Two (2) Pig Launchers
Dead oil from the CPF's will be pumped to the I-24 facility, through line heaters and into the onsite
storage tanks. The oil is pumped to two (2) Lease Automatic Custody Transfer (LACT) units, and sold to
the NGL Riverside Terminal. Any oil that is rejected by the LACT will be sent to the I-24 Heated
Separators for reprocessing. Oil and water will then be sent to the onsite storage tanks. Water will be
trucked from the facility. Oil will then be directed from the tanks back to the LACT units and sold at the
NGL Riverside Terminal. Some oil may be trucked from the facility.
Flashing, working and breathing loss vapors from the condensate and water tanks, and overhead gas
from the heater treater will be directed to the ECD's. These ECD's have a vendor guaranteed destruction
efficiency of 95°/a.
The heated separators and line heaters are APEN exempt emission sources, having less than 2 tons per
year of any single criteria pollutant and less than 1 tpy of VOC and NO. (the facility is located within the
nonattainment 8 -hour Ozone Control Area).
ite ,rte,_.!
trr �r.it�cl�c,
f ;ac ilwhcts
�nl m
1184,
Vrodt,ed 0,1;enkti
/Two (2)\,
LACT
Units /
Oft Spec Oil I., Tan,
Hete<1 l,In1,
i�, e I.illks
North Platte I-24 Production Facility
SESW Sec. 24, T5N, R63W
Weld County, Colorado
l. sran Oa Pipehm,
Oil sold via Pipeline
J
<at rc� ,rpa�el,�
(2) Line Heaters
2.5 MMBtu/hr
Single Stage
Separator
Water Trucked Out
�4
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CREEK
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Form APCD-312
APCD Internal Use Only
Received Date
Approved? ❑ Approval Date
Operating and Maintenance Plan Template for
Hydrocarbon Liquid Loadout
Ver. January 27, 2020
The Air Pollution Control Division developed this Operating and Maintenance Plan (O&M Plan) for hydrocarbon
liquid loadout activities that use emissions controls, permitted at synthetic minor and major oil and gas facilities
in the State of Colorado. One O&M Plan may be used for multiple loadouts at one facility if each are controlled
and monitored in the same manner.
An O&M Plan shall be submitted with the permit application when required. The facility operator must comply
with the requirements of the O&M Plan upon commencement of operation. An existing approved O&M Plan may
be modified without a permit modification or permit reissuance, but the operator must adhere to the requirements
of the existing approved O&M Plan until an approval letter is issued for the new O&M Plan.
The operator is required to use the division -developed O&M Plan template forms in order to meet minimum
expectations within a standard, organized format. Do not modify the structure and/or content of this template.
If the facility or emissions unit is subject to other state or federal regulations with duplicative requirements, the
operator must follow the most stringent regulatory requirement.
Please note that O&M requirements are different for facilities in the Denver Metro and North Front Range 8 -hour
ozone nonattainment area.
For sources that are subject to the Title V Operating Permits program: In accordance with Colorado
Regulation No. 3, Part C, Section V.C.5., some or all of the monitoring specified in this O&M plan will be
incorporated as specific conditions in the source's Title V Operating Permit (if applicable). Additional monitoring
not listed in this O&M Plan may be included in the source's Operating Permit in order to satisfy the periodic
monitoring requirements of Regulation No. 3, Part C, Section V.C.5.b.
Submittal Date: May 2020
Section 1 - Source Identification
For new permits, some of this information (i.e., Facility AIRS ID, Permit Number, and AIRS Point ID) may not be known at the
time of application. Please only fill in the fields that are known and leave the others blank.
Company Name:
Facility Name:
Bonanza Creek Energy
Operating Company, LLC
(BCEOC)
North Plate J -24/I-24
Production Facility
(COGCC #429060/XXXXXX)
Is this facility located in the Denver
Metro and North Front Range 8 -hour
ozone nonattainment area?
Facility Equipment ID
Permit Number
® Yes
❑ No
Facility Location: SESW Sec 24 T5N R63W
(40.378678,-104.388812)
Facility AIRS ID (for existing facilities) 123 - 9A5F
Loadout Sources Covered by this O&M form
L-02
12WE2994 13
Page 1 of 4
GDPHE
COLORADO
Air Pollution Control Division
Department of Public Health £r Environment
AIRS Point ID 020
Section 2 - Maintenance Schedules
Check one of the following:
Facility shall follow manufacturer recommendations for the operation and maintenance of the emissions
unit and control devices. These schedules and practices, as well as all maintenance records showing
compliance with these recommendations, shall be made available to the division upon request.
Facility shall follow individually developed maintenance practices and schedules for the operation and
maintenance of the emissions unit and control devices. These schedules and practices, as well as all
maintenance records showing adherence to these practices, shall be made available to the division upon
request and shall be consistent with good air pollution control practices for minimizing emissions as
defined in the New Source Performance Standard (NSPS) general conditions.
Section 3 - Recordkeeping Requirements
The following box must be checked for the O&M Plan to be considered complete:
Synthetic minor and major sources are required to maintain maintenance and monitoring records for
the requirements of this OEM Plan for a period of five (5) years. If applicable state requirements or
any Federal NSPS, NESHAP, or MACT require a longer record retention period, the operator must comply
with the longest record retention requirement.
Section 4 -Monitoring Requirements
Control Equipment Information
Check the appropriate box below that describes the technique used to collect truck loadout vapors.
Vapor balance connects the truck vapor headspace to the storage tanks, and the displaced vapors are
controlled along with storage tank vapors.
Direct connection to combustion device, not via storage tanks.
Other (describe in Section 5).
Page 2 of 4
CDPHE
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Table 1 below details the monitoring parameters and frequency for control equipment depending on the type of
control equipment and the requested permitted emissions at the facility. Indicate the emissions control by
checking the appropriate boxes. In addition, check the appropriate box for "Monitoring Frequency" based on the
facility attainment area status and facility -wide permitted VOC emissions.
Table 1
Emissions Control
or
Recycling Method
Parameter
Monitoring Frequency
Ozone Nonattainment Area
Ozone Attainment Areas
❑ Permitted
Facility
Emissions
≥ 40 tpy VOC
Permitted
Facility
Emissions
≥ 80 tpy VOC
❑ Permitted
Facility
Emissions
< 80 tpy VOC
/1 Permitted
Facility
Emissions
< 40 tpy VOC
Enclosed Flare
or Elevated
Open Flare a
Pilot Light / Auto -
igniter Monitoring
and
Visible Emissions
Observation
Daily b. c
Weekly b. `
Daily b, c
Weekly b -
►1
Vapor Recovery
Unit (VRU) or
Recycled or
Closed Loop
System
Monitoring requirements, including parameters and frequency, to be determined by the
operator and listed below in footnote d.
Other
❑
Monitoring requirements, including specific parameters and frequency, to be described
in Section 5 below, and approved by the division.
a Elevated Open Flare
An open flare permitted after May 1, 2014 and used to comply with Regulation No. 7 Section XVII must be
approved by the division as an alternate emission control device prior to operation, in accordance with
Regulation No. 7 Section XVI1.B.2.e.; see PS Memo 15-03.
b Pilot Light Monitoring Options
If emissions are controlled by combustion device, then the operator must indicate in Table 2 the method by
which the presence of a pilot light will be monitored. One primary method for Pilot Light Monitoring must be
checked and, optionally, secondary methods may be checked.
Table 2: Pilot Light Monitoring
Primary
Secondary
Monitoring Method
/1
❑
Visual Inspection
_
❑
Optical Sensor
_
❑
Auto -Igniter Signal
i
Thermocouple
Page 3 of 4
COLORADO
Air Pollution Control Division
Department of Public Health Et Environment
Visible Emissions Observation and Method 22 Options
At the frequency specified in Table 1, the operator is required to conduct an inspection of the subject combustion
device for the presence or absence of smoke (e.g., visible emissions). If smoke is observed during the visible
emissions inspection the operator has the option to either (1) immediately shut-in the emissions unit to
investigate the cause of the smoke, conduct any necessary repairs, and maintain records of the specific repairs
completed; or (2) conduct a formal Method 22 observation to determine whether visible emissions (as defined
per Regulation No. 7, Section XVII.A.17.) are present.
If a Method 22 is conducted, the record of the observations shall be maintained as required in Section 3 of this
OEM Plan (Reference: Regulation No. 7, Section XVII.C.3.d). If visible emissions are observed by Method 22, the
operator shall immediately conduct any necessary repairs and maintain records of the specific repairs completed;
if repair cannot be immediately completed, the operator shall shut-in the emissions unit, conduct any necessary
repairs, and maintain records of the specific repairs completed.
If the emissions unit is subject to Regulation No. 7, Section XII.E, operators must document the required
inspections for the presence or absence of smoke. The division has historically approved a "check box" to satisfy
the documentation procedures referenced in Section XI1. The division will continue to accept the "check box"
recordkeeping format in instances where no visible emissions are observed in order to demonstrate compliance
with Regulation No. 7 Section XII.E.4.a.
If a flare is not subject to Regulation No. 7 requirements (as described in the permit), a similar approach may
be employed where the operator may conduct an inspection for presence or absence of smoke, and if smoke is
observed the operator has the option to (1) immediately conduct repairs and maintain records of the specific
repairs completed; (2) shut-in the emissions unit to investigate the cause of the smoke, conduct any necessary
repairs, and maintain records of the specific repairs completed; or (3) conduct a formal Method 9 observation
to determine the opacity of the visible emissions, and conduct repairs if necessary.
d Vapor Recovery Unit (VRU) or Recycled or Closed Loop System
In the space provided below, please provide a description of the emission control or recycling system, including
an explanation of parameters monitored, monitoring frequency, and how the system design ensures that
emissions are being routed to the appropriate system at all times, or during all permitted runtime. Also, provide
a description of how downtime is tracked and recorded.
N/A
Section 5 - Additional Notes and O&M Activities
Please use this section to describe any additional notes or operation and maintenance activities, or if additional
space is needed from a previous section. Attach additional pages if necessary.
N/A
Page 4 of 4
Form APCD-309
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
APCD Internal Use Only
Received Date
Approved? ❑ Approval Date
Operating and Maintenance Plan Template for
Separators'
Ver. January 27, 2020
' This term "separators" is intended throughout to include two-phase separators, three-phase separators, high/low pressure
separators, heater -treaters, vapor recovery towers, etc., and the associated air pollution control equipment.
The Air Pollution Control Division developed this Operating and Maintenance Plan (OEtM Plan) for separators that
use emissions controls, permitted at synthetic minor and major oil and gas facilities in the State of Colorado. One
oam Plan may be used for multiple separators at one facility if each are controlled and monitored in the same
manner.
An OEtM Plan shall be submitted with the permit application when required. The facility operator must comply
with the requirements of the O&M Plan upon commencement of operation. An existing approved O8M Plan may
be modified without a permit modification or permit reissuance, but the operator must adhere to the requirements
of the existing approved OEtM Plan until an approval letter is issued for the new OftM Plan.
The operator is required to use the division -developed O6tM Plan template forms in order to meet minimum
expectations within a standard, organized format. Do not modify the structure and/or content of this template.
If the facility or emissions unit is subject to other state or federal regulations with duplicative requirements, the
operator must follow the most stringent regulatory requirement.
Please note that OaM requirements are different for facilities in the Denver Metro and North Front Range 8 -hour
ozone nonattainment area.
For sources that are subject to the Title V Operating Permits program: In accordance with Colorado
Regulation No. 3, Part C, Section V.C.5., some or all of the monitoring specified in this OEtM plan will be
incorporated as specific conditions in the source's Title V Operating Permit (if applicable). Additional monitoring
not listed in this OEtM Plan may be included in the source's Operating Permit in order to satisfy the periodic
monitoring requirements of Regulation No. 3, Part C, Section V.C.5.b.
Submittal Date: May 2020
Section 1 - Source Identification
For new permits, some of this information (i.e., Facility AIRS ID, Permit Number, and AIRS Point ID) may not be known at the
time of application. Please only fill in the fields that are known and leave the others blank.
Company Name:
Facility Name:
Bonanza Creek Energy
Operating Company, LLC
(BCEOC)
North Plate J -24/I-24
Production Facility
(COGCC #429060/XXXXXX)
Is this facility located in the Denver
Metro and North Front Range 8 -hour
ozone nonattainment area?
Facility
Location:
SESW Sec 24 T5N R63W
(40.378678,-104.388812)
Facility AIRS ID (for existing facilities) 123 - 9A5F
® Yes
❑ No
Emission Units Covered by this 0&M form
Page 1 of 5
CDPHE
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Facility Equipment ID TBD
Permit Number
AIRS Point ID
12WE2994 13
O21
Section 2 - Maintenance Schedules
Check one of the following:
Facility shall follow manufacturer recommendations for the operation and maintenance of the emissions
unit and control devices. These schedules and practices, as well as all maintenance records showing
compliance with these recommendations, shall be made available to the division upon request.
Facility shall follow individually developed maintenance practices and schedules for the operation and
maintenance of the emissions unit and control devices. These schedules and practices, as well as all
® maintenance records showing adherence to these practices, shall be made available to the division upon
request and shall be consistent with good air pollution control practices for minimizing emissions as
defined in the New Source Performance Standard (NSPS) general conditions.
Confirm the following requirement, if the separator has a pressure relief valve (PRV):
The operator shall inspect the separator pressure relief valve (PRV) at a minimum once every calendar
year. The inspection shall include a check that the PRV set point is adequate to ensure that emissions
are routed to the emissions control device during normal operation. Records of these inspections, and
any repairs, shall be made available to the division upon request.
Section 3 - Recordkeeping Requirements
The following box must be checked for the O&M Plan to be considered complete:
Synthetic minor and major sources are required to maintain maintenance and monitoring records for
the requirements of this O&M Plan for a period of five (5) years. If applicable state requirements or
any Federal NSPS, NESHAP, or MACT require a longer record retention period, the operator must comply
with the longest record retention requirement.
Page 2 of 5
I
CDPHE
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Section 4 - Monitoring Requirements
Emission Unit Information
The following boxes must be checked for the O&M Plan to be considered complete:
Attach a diagram or plot plan of the configuration of the separator(s), control device(s), and vapor
recovery unit(s), as well as the location(s) of flow meters. This diagram is required in addition to the
facility -wide diagram required for new permit applications. This diagram shall be retained with the
OEM Plan for reference by the operator and division inspector.
The permit requires calculation and recordkeeping of actual emissions from this source, but the calculation
methods are not incorporated into the permit. In the space below, describe the formulas used to calculate the
volume of gas vented from the separator and sent to the control device, using data from the meter if required.
If using a vapor recovery tower (VRT), describe the method used to calculate the volume of gas vented from the
VRT. If the permit throughput limit is in terms of hydrocarbon liquid, then in the space below describe how the
liquid throughput shall be tracked.
Examples:
Flow meter at enclosed flare directly measures the volume of gas sent to flare from a single separator.
OR
Volume from low pressure separator sent to control device = (Metered volume through high pressure separator) - (Metered volume through low pressure separator)
OR
Volume vented from VRT = (Total gas volume metered at flare) - (Metered volume to flare from low pressure separator) - (Volume to flare from tanks)
OR
Permit throughput limit is based on hydrocarbon liquid, which is tracked by tank inlet meter, with backup of sales/haul tickets.
OR etc.
Please be clear and specific about the sources of input data, and describe how the input data is collected and recorded. Attach additional pages if needed.
Flow meter at enclosed flare directly measures the colume of gas sent to flare from heater treater.
Page 3 of 5
cDPHE
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Control Equipment Information
Table 1 below details the monitoring parameters and frequency for control equipment depending on the type of
control equipment and the requested permitted emissions at the facility. Indicate the separator emissions control
by checking the appropriate boxes. In addition, check the appropriate box for "Monitoring Frequency" based on
the facility attainment area status and facility -wide permitted VOC emissions.
Table 1
Emissions Control
or
Recycling Method
Parameter
Monitoring Frequency
Ozone Nonattainment Area
Ozone Attainment Areas
❑ Permitted
Facility
Emissions
a 40 tpy VOC
❑ Permitted
Facility
Emissions
a 80 tpy VOC
Permitted
Facility
Emissions
< 80 tpy VOC
►1 Permitted
Facility
Emissions
< 40 tpy VOC
Enclosed Flare
or Elevated
Open Flare a
Pilot Light / Auto -
igniter Monitoring
and
Visible Emissions
Observation
Daily b' c
Weekly b. c
Daily b. c
Weekly b'
�.
Vapor Recovery
Unit (VRU) or
Recycled or
Closed Loop
System
❑
Monitoring requirements, including parameters and frequency, to be determined by the
operator and listed below in footnote d.
Other
M
Monitoring requirements, including specific parameters and frequency, to be described
a Elevated Open Flare
An open flare permitted after May 1, 2014 and used to comply with Regulation No. 7 Section XVII must be
approved by the division as an alternate emission control device prior to operation, in accordance with
Regulation No. 7 Section XVI1.B.2.e.; see PS Memo 15-03.
b Pilot Light Monitoring Options
If emissions are controlled by combustion device, then the operator must indicate in Table 2 the method by
which the presence of a pilot light will be monitored. One primary method for Pilot Light Monitoring must be
checked and, optionally, secondary methods may be checked.
Table 2: Pilot Light Monitoring
Primary
Secondary
Monitoring Method
►1
❑
Visual Inspection
❑
Optical Sensor
❑
_❑
_
Auto -Igniter Signal
❑
Thermocouple
Page 4 of 5
CDPHE
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Visible Emissions Observation and Method 22 Options
At the frequency specified in Table 1, the operator is required to conduct an inspection of the subject combustion
device for the presence or absence of smoke (e.g., visible emissions). If smoke is observed during the visible
emissions inspection, the operator has the option to either (1) immediately shut-in the emissions unit to
investigate the cause of the smoke, conduct any necessary repairs, and maintain records of the specific repairs
completed; or (2) conduct a formal Method 22 observation to determine whether visible emissions (as defined
per Regulation No. 7, Section XVII.A.16.) are present.
If a Method 22 is conducted, the record of the observations shall be maintained as required in Section 3 of this
0&M Plan (Reference: Regulation No. 7, Section XVII.C.3.d). If visible emissions are observed by Method 22, the
operator shall immediately conduct any necessary repairs and maintain records of the specific repairs completed;
if repair cannot be immediately completed, the operator shall shut-in the emissions unit, conduct any necessary
repairs, and maintain records of the specific repairs completed.
If the emissions unit is subject to Regulation No. 7, Section XII.E, operators must document the required
inspections for the presence or absence of smoke. The division has historically approved a "check box" to satisfy
the documentation procedures referenced in Section XI1. The division will continue to accept the "check box"
recordkeeping format in instances where no visible emissions are observed in order to demonstrate compliance
with Regulation No. 7 Section XII.E.4.a.
If a flare is not subject to Regulation No. 7 requirements (as described in the permit), a similar approach may
be employed where the operator may conduct an inspection for presence or absence of smoke, and, if smoke is
observed, the operator has the option to (1) immediately conduct repairs and maintain records of the specific
repairs completed; (2) shut-in the emissions unit to investigate the cause of the smoke, conduct any necessary
repairs, and maintain records of the specific repairs completed; or (3) conduct a formal Method 9 observation
to determine the opacity of the visible emissions, and conduct repairs if necessary.
d Vapor Recovery Unit (VRU) or Recycled or Closed Loop System
In the space provided below, please provide a description of the emission control or recycling system, including
an explanation of parameters monitored, monitoring frequency, and how the system design ensures that
emissions are being routed to the appropriate system at all times, or during all permitted runtime. Also, provide
a description of how downtime is tracked and recorded. Attach additional pages if necessary.
N/A
Section 5 - Additional Notes and OttM Activities
Please use this section to describe any additional notes or operation and maintenance activities, or if additional
space is needed from a previous section. Attach additional pages if necessary.
N/A
Page 5 of 5
a /SO bbl
�•r.yciut�A f,�I Tanks
C)il its 1 arks
7 Two (2I ',
LACt {
Units
Oltto keino [arks
°il truck Loading
1, 1O i.,nk.
North Platte I-24 Production Facility
SESW Sec. 24, TSN, R63W
Weld County, Colorado
ftw�ect 3'nn k.
Oil sold via Pipeline
J
O0 to set,aiar„
1 2.5 MMStu/hr(2( line Heaters
Single Stage
Separator
1 - ISJ
bb! P,77
Tanks
Water Trucked Out
S4
eonrinn
CREEK
ATTACHMENT I
Regulatory Applicability Information
This document provides regulatory applicability information to supplement the construction
permit application for Bonanza Creek Energy Operating Company, LLC's North Platte J -24/I-24
Production Facility (COGCC #429060). An analysis of the applicability of state and federal air
quality permitting requirements and air pollution control regulations for the emissions
sources is provided, along with an appropriate explanation and rationale regarding the
applicability or non -applicability of specific regulations for the emissions sources.
Regulation 3: Permitting and APEN Requirements
Regulation 3, Part A, Section II: The heated separators, pneumatic devices, produced water
vault, mixed materials truck loading, mixed materials tanks, line heaters, fugitive, and PIG
emissions are not subject to APEN reporting. Uncontrolled actual emissions of all criteria
pollutants (except volatile organic compounds [VOC] and nitrogen oxides [NOx]) are less than
2 ton per year (tpy), and NOx and VOC emissions are less than 1 tpy within the nonattainment
8 -hour Ozone Control Area [Regulation 3, Part A.II.B.3.a and Part A.II.D.1.a].
Regulation 3, Part B, Section II: The heated separators, pneumatic devices, produced water
vault, mixed materials truck loading, mixed materials tanks, line heaters, fugitive, and PIG
emissions are not subject to permitting because they are not subject to APEN reporting
[Regulation 3, Part B.II.D.1.a].
Condensate Truck Loading is subject to permitting because the site is an exploration and
production facility that submerge fills more than 16,308 barrels of condensate per year
[Regulation 3, Part B.II.D.1.1].
Regulation 3, Part B, Section III: Sources completing a permit to construct in designated
nonattainment areas with projected controlled annual emissions of any pollutant for which an
ambient air quality standard has been designated where such emissions will be greater than 25
tpy are subject to public comment and hearing requirements. The facility is subject to these
regulations because VOC emissions are greater than 25 tpy [Regulation 3, Part B.III.C.1.a].
Regulation 3 requires that new minor sources in designated nonattainment areas shall apply
Reasonably Available Control Technology (RACT) for the pollutants for which the area is
nonattainment or attainment/maintenance. The facility is a synthetic minor source within a
nonattainment area and is required to apply RACT to facility sources of NO, and VOCs. The
facility has met these requirements by following applicable requirement of Regulation 7 for
sources of NOx and VOCs on site.
Regulation 3, Part C: This facility will continue to operate as a synthetic minor source with
respect to the Title V Operating Permit Program. The facility will not be required to submit a
Title V Permit application within 12 months of startup.
Regulation 3, Part D: This facility is not a listed source in Regulation 3, Part D, Section II.A.25
and therefore would trigger Prevention of Significant Deterioration (PSD) requirements if
emissions exceed 250 tpy of any criteria pollutant. The facility is located in the nonattainment
8 -hour Ozone Control Area where a major source for non -attainment new source review (NA-
NSR) has the potential to emit more than 50 tpy for VOCs or NOx. This facility as proposed will
be a synthetic minor stationary source with respect to PSD and NA-NSR; therefore, it is not
subject to this regulation.
Regulation 7, Part D Section I Oil and Gas Ozone Control Area Regulations
1
Regulation 7, Part D Section I.C: Section II.C applies to all condensate collection, storage and
handling facilities located in the 8 -hour Ozone Control Area. All new or modified storage
tanks after February 1, 2009 must control VOC by at least 95% during the first 90 days of
production. Any combustion device installed after January 1, 2017 must be
equipped with an auto -igniter. The tanks are subject to this section and were controlled
during the first 90 days of production. The combustion devices on site were installed after
January 1, 2017 and are equipped with auto -ignitors.
Regulation 7, Part D Section I.D.3 and I.F.2 and I.F.3: These sections apply to all condensate
collection, storage and handling facilities with uncontrolled actual VOC emissions greater than
2 tpy in the 8 -hour Ozone Control Area. Storage Tanks constructed on or after March 1, 2020
must control VOC emissions by at least 95% upon commencement of operations. Storage Tanks
constructed prior to March 1, 2020 must control VOC emissions by at least 95% by May 1, 2020.
Storage tanks must install controls within 60 days of exceeding 2 tpy uncontrolled actual VOC
emissions. The produced water and oil storage vessels are all manifolded together via a liquid
line and therefore are considered one "storage tank" for applicability purposes. The total
emissions from the storage tank exceed 2 tpy uncontrolled actual VOC emissions and are subject
to these sections.
Regulation 7, Part D Section I.E: Section I.E applies to all existing storage tanks at oil and gas
production facilities required to be controlled under Regulation 7, Part D Section I.
Audio, visual, olfactory (AVO) inspections are required not more than every seven (7) days but
at least every thirty one (31) days until April 30, 2020. Starting May 1, 2020 weekly AVO
inspections are required. The storage tanks at this facility are required to install control
equipment per Section I.D and are thus subject inspection, recordkeeping and reporting
requirements of this section.
Regulation 7, Part D Section I.K: This section applies to pneumatic pumps located at gas plants
and well production facilities in the 8 -hour Ozone Control Area. Pneumatic pumps that operate
more than 90 days per year at well production facilities must route emissions to an existing
control device that can control VOC emission by at least 95% if technically feasible. The
pneumatic pumps at this facility are subject to this section.
Regulation 7, Part D Section I.L: Section I.L applies to well production facilities with
uncontrolled actual VOC emissions greater than 1 tpy (highest emitting tank or facility wide
emissions) and all natural gas compressor stations located in the 8 -hour Ozone Control area.
Compressor stations must conduct leak inspections quarterly starting within 90 days of startup.
Well production facilities must conduct leak inspections annually or semi-annually (depending
on emissions) starting within 30 days of commencing operations. This facility is considered a well
production facility with storage tanks. Based on the uncontrolled VOC emissions, this facility is
required to perform leak inspections on a semi-annual basis.
Regulation 7, Part D Section II Oil and Gas State -Wide Regulations
Regulation 7, Part D Section II.C.1.: This section applies to all condensate collection, storage and
handling facilities with uncontrolled actual VOC emissions greater than 2 tpy statewide. Storage
Tanks constructed on or after March 1, 2020 must control VOC emissions by at least 95% upon
commencement of operations. Storage Tanks constructed prior to March 1, 2020 must control
VOC emissions by at least 95% by May 1, 2021. The produced water and oil storage vessels are all
manifolded together via a liquid line and therefore are considered one "storage tank" for
applicability purposes. The total emissions from the storage tank exceed 2 tpy uncontrolled actual
VOC emissions and are subject to this section.
2
Regulation 7, Part D Section II.C.2 and II.C.3.: Section II.C.2 and II.C.3 applies to all storage
tanks at oil and gas production facilities required to be controlled under Regulation 7,
Part D Section I.D or II.C.1. A STEM plan must be developed and followed. Inspections
of the storage tank must occur Monthly, quarterly or semi-annually (depending on emissions).
The storage tanks are subject to control requirements under both I.D and II.C.1 and is therefore
subject to this section. Based on the uncontrolled VOC emissions, this facility is required to
perform STEM inspections on a semi-annual basis.
Regulation 7, Part D Section II.C.4.: Section II.C.4 applies to all storage tanks at oil and gas
production facilities, compressor stations and gas processing plants constructed or modified on
or after May 1, 2020. Storage tanks constructed or modified on or after May 1, 2020 must
install equipment to determine quantity of liquid stored. Storage tanks constructed
or modified on or after January 1, 2021 must install equipment to determine quantity
and quality of liquid stored. Signage must be posted and annual training is required. This
regulation does not apply to the storage tanks onsite because they were constructed prior to May
1, 2020 and have not been modified.
Regulation 7, Part D Section II.C.5.: Section II.C.4 applies to oil and gas production facilities,
compressor stations and gas processing plants that loadout 5,000 barrels per year or more of
hydrocarbon liquids. Facilities are required to use submerged fill and vapor return or control
equipment. Facilities constructed on or after May 1, 2020 must be in compliance upon startup.
Facilities constructed before May 1, 2020 must be in compliance by May 1, 2021. The facility is
subject to this section because it loads out more than 5,000 barrels of hydrocarbon liquid per year.
Regulation 7, Part D Section II.E.4: Section II.E.4 applies to well production facilities with
uncontrolled actual VOC emissions greater than 1 tpy (highest emitting tank or facility wide
emissions) and all natural gas compressor stations. This facility is considered a well production
facility with storage tanks that is not within 1,000 feet of an occupied area. Based on the
uncontrolled VOC emissions from the highest emitting tank, this facility is required to perform
AIMM inspections quarterly and AVO inspections monthly.
Regulation 7, Part D Section II.F: Section II.F applies to gas coming off a separator produced
during "normal" operations from newly construction, hydraulically fractured, or recompleted
wells after August 1, 2014. This facility is subject to the gathering and control requirements of
Part D II.F because the wells onsite were constructed after August 1, 2014.
Regulation 7, Part D Section II.G: Section II.G applies to downhole well maintenance, well
liquids unloading events, and well plugging events. This facility is subject to the best
management practices, record keeping and report requirements of this rule for any
downhole well maintenance, well liquids unloading events, and well plugging events that occur
on site.
Regulation 7, Part D Section III: Section III applies to pneumatic controllers that are placed
in service on or after February 1, 2009 in nonattainment areas, and pneumatic controllers
statewide that are placed in service on or after May 1, 2014. The facility is located inside the non -
attainment area and has complied with this regulation by installing only pneumatic controllers
that emit VOCs in an amount less than or equal to a low -bleed pneumatic controller. This facility
will follow the inspection, enhanced response, record keeping and reporting requirements.
Regulation 7, Part D Section V: Section V requires oil and natural gas operations and
equipment at or upstream of a natural gas processing plant submit an annual actual emissions
report. The facility is located upstream of a natural gas processing plant and will follow the
reporting requirements of this section.
3
40 CFR 60, New Source Performance Standards
40 CFR 60 Subpart Kb - Standards of Performance for Volatile Organic Liquid Storage
Vessels (Including Petroleum Liquid Storage Vessels): Subpart Kb applies to storage vessels
which commence construction, modification or reconstruction after July 23, 1984. The storage
tanks located at the facility are subject to the requirements of this subpart under
§60.110b(d)(4), as they are used for condensate storage after custody transfer and have a
capacity greater than 151 m3.
40 CFR 60 Subpart OOOO - Standards of Performance for Crude Oil and Natural gas
Production, Transmission and Distribution for which Construction, Modification or
Reconstruction Commenced after August 23, 2011, and on or before September 18, 2015:
Subpart OOOO applies to affected facilities that commenced construction, reconstruction, or
modification after August 23, 2011 and on or before September 18, 2015. Affected facilities
include: gas well affected facilities; centrifugal compressors with wet seal degassing systems;
reciprocating compressors; continuous -bleed natural gas actuated pneumatic controllers;
storage vessels containing crude oil, condensate, produced water or a mixture thereof;
equipment leaks of VOC at natural gas processing plants; and sweetening units at natural gas
processing plants constructed, modified or reconstructed after August 23, 2011 and on or before
September 18, 2015. This facility is a well site and is neither a compressor station nor a natural
gas processing plant.
Storage Vessel Affected Facility: Each storage vessel constructed after August 23, 2011 and
before September 18, 2015, that emits VOC emissions at or greater than 6 tons per year
(as determined by the maximum average daily throughput) is subject to the emissions
control (95% DRE), recordkeeping and reporting requirements of this subpart. Legally
and practically enforceable limits may be accounted for in determining VOC emission
from storage vessels for applicability to this subpart. The J-24 storage tanks onsite
were constructed in June 2012, however the storage tanks emits less than 6 tons per year
after accounting for legally and practically enforceable limits, and as such the J-24 storage
vessels are not an affected facility under this subpart. The I-24 storage tanks will be
constructed after September 18, 2015 and are therefore not an affected facility under this
subpart.
Pneumatic Controller Affected Facility: All continuous bleed pneumatic controllers must be
low or no bleed (≤6 scf/hr natural gas bleed rate). High bleed pneumatic controllers, if
they must be used, are subject to the tagging and reporting requirements of this subpart.
All pneumatic controllers at the site are either intermittent, low (≤6 scf/hr natural gas
bleed rate) or no bleed and as such not applicable to the tagging and reporting
requirements of this subpart.
40 CFR 60 Subpart 0000a - Standards of Performance for Crude Oil and Natural Gas
Facilities for which Construction, Modification or Reconstruction Commenced After
September 18, 2015: Subpart 0000a regulates certain: well affected facilities (oil and gas
wells); centrifugal compressors with wet seal degassing systems; reciprocating compressors;
continuous -bleed natural gas actuated pneumatic controllers; storage vessels containing crude
oil, condensate, produced water or a mixture thereof; equipment leaks of VOC at natural gas
processing plants; sweetening units at natural gas processing plants; pneumatic pump affected
facilities; and the collection of fugitive emissions components at a well site or at a compressor
station constructed, modified or reconstructed after September 18, 2015. The site is considered a
well site under this regulation.
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Storage Vessel Affected Facility: Each storage vessel that emits VOC emissions at or greater
than 6 tons per year (as determined by the maximum average daily throughput) is
subject to the emissions control (95% DRE), recordkeeping and reporting requirements
of this subpart. Legally and practically enforceable limits may be accounted for in
determining VOC emissions from storage vessels for applicability to this subpart. The J-
24 storage vessels were constructed prior to September 18, 2015 and are therefore not an
affected facility under OOOOa. The I-24 storage vessels will be constructed after
September 18, 2015, however the storage tanks emits less than 6 tons per year after
accounting for legally and practically enforceable limits, and as such the I-24 storage
vessels are not an affected facility under this subpart.
Pneumatic Controller Affected Facility: All continuous bleed pneumatic controllers must be
low or no bleed (≤6 scf/hr natural gas bleed rate). High bleed pneumatic controllers, if
they must be used, are subject to the tagging and reporting requirements of this subpart.
All pneumatic controllers at the site are either intermittent, low (≤6 scf/hr natural gas
bleed rate) or no bleed and as such not applicable to the tagging and reporting
requirements of this subpart.
Pneumatic Pump Affected Facility: Pneumatic pumps at well sites that operate more than
90 days per year are required to control emissions (95% DRE) or submit a certification
that routing to a control device is technically infeasible. The pneumatic pump at North
Platte J-24 is routed to a combustor that controls emissions to 95% or greater.
Collection of Fugitive Emissions Components: The collection of fugitive emission
components located a well site are subject to a Leak Detection and Repair (LDAR)
program. The facility was constructed prior to September 18, 2015 and no modifications
have occurred.
40 CFR 60, National Emission Standards for Hazardous Air Pollutants
40 CFR 63 Subpart HH - National Emission Standards for Hazardous Air Pollutants from Oil and
Natural Gas Production Facilities: Subpart HH applies to certain glycol dehydration units, storage
vessels with the potential for flashing, and fugitive equipment (at gas plants) at major sources of
HAP emissions and certain triethylene glycol (TEG) dehydration units at area sources of HAP
emissions. This facility is considered an area source with respect to HAPs. There are no dehydrators
proposed for this facility, therefore, according to §63.760(b)(2) & (d) this facility will not be subject
to the requirements of this subpart.
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