HomeMy WebLinkAbout20203703.tiff COLORADO
4,. ,4 Department of Public
Health&Environment
RECEIVED
Weld County - Clerk to the Board
1150 O St NOV 3 0 2020
PO Box 758
Greeley, CO 80632 WELD COUNTY
COMMISSIONERS
November 23, 2020
Dear Sir or Madam:
On November 24, 2020, the Air Pollution Control Division will begin a 30-day public notice period for
Bonanza Creek Energy Operating Company, LLC - Pronghorn 11-14-5HZ Production Facility. A copy of
this public notice and the public comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 vdww.cotorado.gov/cdphe ( IiFly 6!,:,,,
Jared Polls, Governor I Jill Hunsaker Ryan,MPH, Executive Director * _ ,*.
Po b( -.c. Re V e(,J cc..PL(TP),HLCPS),Pw(3M/ER/04/cx) 2020-3703
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C ,,r: .. Air Pollution Control Division
4 -- ,Iwi.r.-- Notice of a Proposed Project or Activity Warranting Public
CDPHE
Comment
Website Title: Bonanza Creek Energy Operating Company, LLC - Pronghorn 11-14-5HZ Production Facility -
Weld County
Notice Period Begins: November 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: Pronghorn 11-14-5HZ Production Facility
This facility is a well production facility.
NWNW Section 5, T5N, R61W
Weld County
The proposed project or activity is as follows: Modification of throughput limitations for condensate storage
tanks and separators to be reflective of current facility operations; additional modification of throughput
limitations and emission factors for condensate truck loadout.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 12WE1828 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.Rov/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:
Elie Chavez
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
ICOLORADic
Department of Public
1 I ilaW. GDPNE Health b Environment
C .`:-r- COLORADO
Air Pollution Control Division
Department of Public Health B Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 12WE1828 Issuance: 5
Date issued:
Bonanza Creek Energy Operating
Issued to: Company, LLC
Facility Name: Pronghorn 11-14-5HZ Production Facility
Plant AIRS ID: 123/9892
Physical Location: NWNW SEC 5 T5N R61 W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment Point Equipment Description Description
ID
Six (6) 400 barrel fixed roof storage vessels
CNDTK-01 001 Enclosed Flare(s)
used to store condensate
Two (2) 300 barrel fixed roof storage
PWT-01 003 vessels used to store produced water Enclosed Flare(s)
L-01 004 Truck loadout of condensate by submerged Enclosed Flare(s)
fill using vapor balance
One natural gas driven pneumatic pump for
P-01 012 heat trace. Sandpiper G1F Serial # 1902022 Enclosed Flare(s)
rated at 600 scf/hr
One pneumatic water transfer pump, rated
P-02 015 at 600 scf/hr (Sandpiper, Model G1F, Serial Enclosed Flare(s)
number 2091563)
LPGFL 016 Two (2) high/low pressure (HLP) separators Enclosed Flare(s)
Points 012 and 015: This pump may be replaced with another pump in accordance with the
provisions of the Alternate Operating Scenario (AOS) in this permit.
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to
Page 1 of 16
C :- COLORADO
~ Air Pollution Control Division
�i�� Department of Putalie Health El Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
the specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. This construction permit represents final permit approval and authority to operate this
emissions source. Therefore, it is not necessary to self-certify. (Regulation Number 3, Part B,
Section III.G.5.)
EMISSION LIMITATIONS AND RECORDS
2. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
)
Annual Limits:
Facility AIRS _ Tons per Year Emission
Equipment ID Point PM2.5 NOX- VOC CO Type
CNDTK-01 001 -- 8.3 -- Point
PWT-01 003 -- -- 0.8 -- Point
L-01 004 -- -- 0.4 -- Point
P-01 012 -- -- 2.3 Point
P-02 015 -- - 2.3 -- Point
LPGFL 016 -- -- 25.8 4.2 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.
3. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
4. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Page 2 of 16
. . COLORADO
Air Pollution Control Division
COCK.
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
CNDTK-01 001 Enclosed Flare(s) VOC and HAPs
PWT-01 003 Enclosed Flare(s) VOC and HAPs
L-01 004 Enclosed Flare(s) VOC and HAPs
P-01 012 Enclosed Flare(s) VOC and HAPs
P-02 015 Enclosed Flare(s) VOC and HAPs
LPGFL 016 Enclosed Flare(s) VOC and HAPs
PROCESS LIMITATIONS AND RECORDS
5. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part B,
IIA.4.)
Process Limits
Facility AIRS
Equipment Process Parameter Annual Limit
ID Point
CNDTK-01 001 Condensate Throughput 65,700 barrels
PWT-01 003 Produced Water Throughput 118,260 barrels
L-01 004 Oil Loaded 65,700 barrels
P-01 012 Venting of natural gas 5.3 MMscf
P-02 015 Venting of Natural Gas 5.3 MMscf
LPGFL 016 Gas Vented from Separators 11.0 MMscf
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total 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.
Page 3 of 16
$� COLORADO
Air Pollution Control Division
COPH
Department of Pttbte Health&£nvttonment
Dedicated to protecting and improving the health and environment of the people of Colorado
6. Point 016: Upon installation of the flow meter, the owner or operator shall continuously
monitor and record the volumetric flow rate of natural gas vented from the separator(s) using
the flow meter. The flow meter must be calibrated and maintained per the manufacturer's
specifications and schedule. The owner or operator shall use monthly throughput records to
demonstrate compliance with the process limits contained in this permit and to calculate
emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
7. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
8. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
9. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the
source. During periods of startup, process modification, or adjustment of control equipment
visible emissions shall not exceed 30%opacity for more than six minutes in any sixty consecutive
minutes. (Reference: Regulation No. 1, Section iIA.1. Et 4.)
10. No owner or operator of a smokeless flare or other flare for the combustion of waste gases
shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of
30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive
minutes. (Regulation Number 1, Section II.A.5.)
11. The enclosed flare(s) covered by this permit are subject to Regulation No. 7, Part D, Section
iI.B General Provisions (State only enforceable). All air pollution control equipment shall be
operated and maintained pursuant to the manufacturing specifications or equivalent to the
extent practicable, and consistent with technological limitations and good engineering and
maintenance practices. The owner or operator shall keep manufacturer specifications or
equivalent on file. In addition, all such air pollution control equipment shall be adequately
designed and sized to achieve the control efficiency rates and to handle reasonably foreseeable
fluctuations in emissions of VOCs and other hydrocarbons during normal operations.
Fluctuations in emissions that occur when the separator dumps into the tank are reasonably
foreseeable.
12. The enclosed flare(s) covered by this permit are subject to Regulation Number 7, Part D,
Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion
device is used to control emissions of volatile organic compounds to comply with Section II, it
must be enclosed; have no visible emissions during normal operations, as defined under
Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by
means of visual observation from the outside of the enclosed flare or combustion device, or
by other convenient means approved by the Division, determine whether it is operating
properly. This flare must be equipped with an operational auto-igniter according to the
schedule in Regulation Number 7, Part D, Section II.6.2.d.
13. Point 001: This source is subject to Regulation Number 7, Part D, Section I. The operator
must comply with all applicable requirements of Section I and, specifically, must:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for storage tanks; and
Page 4 of 16
»t. = COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• 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 outsides 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)
14. Point 001: The storage tank covered by this permit is subject to the emission control
requirements in Regulation Number 7, Part D, Section II.C.1. The owner or operator must
install and operate air pollution control equipment that achieves an average hydrocarbon
control efficiency of 95%. If a combustion device is used, it must have a design destruction
efficiency of at least 98% for hydrocarbons except where the combustion device has been
authorized by permit prior to March 1, 2020. The source must follow the inspection
requirements of Regulation Number 7, Part D, Section II.C.1.d. and maintain records of the
inspections for a period of two years, made available to the Division upon request. This
control requirement must be met within 90 days of the date that the storage tank commences
operation.
15. Point 001: The storage tanks covered by this permit are subject to the venting and Storage
Tank Emission Management System ("STEM") requirements of Regulation Number 7, Part D,
Section II.C.2. '
16. Point 004: This source is located in an ozone non-attainment or attainment-maintenance area
and is subject to the Reasonably Available Control Technology (RACT) requirements of
Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted
by submerged fill. (Reference: Regulation 3, Part B, III.E)
17. Point 004: The owner or operator shall follow loading procedures that minimize the leakage of
VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.E):
a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other
liquid or vapor toss during loading and unloading.
b. All compartment hatches (including thief hatches) shall be closed and latched at all
times when loading operations are not active, except for periods of maintenance,
gauging, or safety of personnel and equipment.
c. The owner or operator shall inspect loading equipment and operations on site at the
time of the inspection to ensure compliance with Condition 17 (a) and (b) above. The
inspections shall occur at least monthly. Each inspection shall be documented in a log
available to the Division on request.
18. Point 004: All hydrocarbon liquid loading operations, regardless of size, shall be designed,
operated and maintained so as to minimize leakage of volatile organic compounds to the
atmosphere to the maximum extent practicable.
19. Point 004: Hydrocarbon liquids loadout from storage tanks to transport vehicles must be
controlled by using (a) submerge fill and (b) a vapor collection and return system and/or air
pollution control equipment. Compliance with Section II.C.5. must be achieved in accordance
with the following schedule: (Regulation Number 7, Part D, Section II.C.5.a.)
• Facilities constructed or modified on or after May 1, 2020, must be in compliance by
commencement of operation.
Page 5 of 16
C0 _Sr�:'�. COLORADO
Air Pollution Control Division
Nttiit
Department of Kubik Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• 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.
20. Point 004: Storage tanks must operate without venting at all times during loadout.
(Regulation Number 7, Part D, Section II.C.5.a.(ii))
21. Point 004: The owner or operator must, as applicable (Regulation Number 7, Part D, Section
II.C.5.a.(iii)):
• Install and operate the vapor collection and return equipment to collect vapors during
the loadout of hydrocarbon liquids to tank compartments of outbound transport
vehicles and to route the vapors to the storage tank or air pollution control
equipment.
• Include devices to prevent the release of vapor from vapor recovery hoses not in use.
• Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to
transport vehicles unless the vapor collection and return system is in use.
• Operate all recovery and disposal equipment at a back-pressure less than the pressure
relief valve setting of transport vehicles.
• The owner or operator must inspect onsite loading equipment to ensure that hoses,
couplings, and valves are maintained to prevent dripping, leaking, or other 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.
22. Point 004: The owner or operator must perform the following observations and training
(Regulation Number 7, Part D, Section II.C.5.a.(iv)):
• The owner or operator must observe loadout to confirm that all storage tanks operate
without venting when loadout operations are active. These inspections must occur at
least monthly, unless loadout occurs less frequently, then as often as loadout is
occurring.
• If observation of loadout is not feasible, the owner or operator must document the
annual loadout frequency and the reason why observation is not feasible and inspect
the facility within 24 hours after loadout to confirm that all storage tank thief hatches
(or other access point to the tank) are closed and latched.
• The owner or operator must install signage at or near the loadout control system that
indicates which loadout control method(s) is used and the appropriate and necessary
operating procedures for that system.
• The owner or operator must develop and implement an annual training program 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.
Page 6 of 16
.N•4% COLORADO
Air Pollution Control Division
Department of Public Health fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
23. Point 004: The owner or operator must retain the records required by Regulation Number 7,
Part D, Section II.C.5.a.(v) for at least two (2) years and make such records available to the
Division upon request.
• Records of the annual facility hydrocarbon liquids loadout to transport vehicles
throughput.
• Inspections, including a description of any problems found and their resolution,
required under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log.
• Records of the infeasibility of observation of loadout.
• Records of the frequency of loadout.
• Records of the annual training program, including the date and names of persons
trained.
24. Point 004: Air pollution control equipment used to comply with this Section II.C.5. must
comply with Section II.B , be inspected in accordance with Sections II.C.1.!d.(ii) through (v),
and achieve a hydrocarbon control efficiency of 95%. (Regulation Number 7, Part D, Section
II.C.5.a.(vi))
25. Point 012, 015: This source is subject to the requirements of Regulation Number 7, Part D,
Sections I.C, I K.2, and I.K.3 including but not limited to:
• Beginning May 1, 2018, the owner or operator of each natural gas-driven diaphragm
pneumatic pump located at a well production facility must reduce volatile organic
compound emissions from the pneumatic pump by 95% if it is technically feasible to
route emissions to an existing control device or process at the well production facility.
• All air pollution control equipment used to demonstrate compliance with Section I.K
must meet a control efficiency of at least 95%.
• The combustion device controlling emissions from the pneumatic pump(s) must 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.
• All combustion devices installed on or after January 1, 2018 and used to comply with
Section I.K must be equipped with an operational auto-ignitor upon installation of the
combustion device.
26. Point 016: The separators covered by this permit are subject to Regulation 7, Part D, Section
II.F. On or after August 1, 2014, gas coming off a separator, produced during normal operation
from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must
either be routed to a gas gathering line or controlled from the commencement of operation by
air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%.
If a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
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
Page 7 of 16
r COLORADO
40 it.,�/ Air Pollution Control Division
i�� Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
specified information in the Division-approved report format. The information included in the
annual report must be in accordance with the general reporting requirements of Regulation
Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter,
owners or operators must maintain the information according to Regulation Number 7, Part D,
Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING £t MAINTENANCE REQUIREMENTS
28. Point 001, 003, 004, 012, 015, 016: Upon startup of these points, the owner or operator
must follow the most recent operating and maintenance (08M) plan and record keeping
format approved by the Division, in order to demonstrate compliance on an ongoing basis with
the requirements of this permit. Revisions to the atM plan are subject to Division approval
prior to implementation. (Regulation Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
29. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
30. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ALTERNATE OPERATING SCENARIOS
31. Point 012, 015: 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.
32. Point 012, 015: 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.
33. Point 012, 015: 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
34. All previous versions of this permit are cancelled upon issuance of this permit.
35. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
Page 8 of 16
,�. COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on
the last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• 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.
36. The requirements of Colorado Regulation No. 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B).
With respect to this Condition, Part D requirements may apply to future modifications if
emission limits are modified to equal or exceed the following threshold levels:
Emissions - tons per year
Facility AIRS Equipment Current
Equipment Point Description Pollutant ID Threshold Permit
Limit
CNDTK-01 001 Condensate
Tank
PWT-01 003 Produced
Water Tank VOC 50 44.2
L-01 004 Condensate
Loadout
C-101 005 Engine
Page 9 of 16
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
P-01 012 Pneumatic
Pump
P-02 015 Pneumatic
Pump
LPGFL 016 Separator
Venting
Insignificant
Sources
Note: APEN and permit exempt sources do not have permit limits. However, the PTE of these sources
(excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR.
GENERAL TERMS AND CONDITIONS
37. 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.
38. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization
of the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self-certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self-Certify for Final Authorization section
of this permit.
39. 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.
40. 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.
41. 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
Page 10 of 16
»�: COLORADO
Air Pollution Control Division
Department of Pt blIc Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
42. 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.
43. 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:
Elie Chavez
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 20 November Issued to Bonanza Creek Energy Operating
2012 Company, LLC. For the truck loadout of
condensate at a new, synthetic minor facility.
Issuance 2 3 November Add pneumatic pump (012) to permit.
2014
Issuance 3 7 July 2016 Converted Points 001 and 003 from coverage
under GP's to coverage under traditional
construction permit. Modified Permit Limit of
Point 004. Added a second pneumatic pump
(015), two separators (016), and one emergency
flare (017).
Issuance 4 18 April 2017 Removed VRU from Point 016. Modified
through-put, emission factors, and emissions.
Cancel point 017.
Issuance 5 This Issuance Point 001: Modified throughput and emission
limitations
Point 004: Modified throughput, emission factors
and emission limitations
Point 016: Modified throughput and emission
limitations
Page 11 of 16
C .%x COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this
permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify
the Division of any malfunction condition which causes a violation of any emission limit or limits
stated in this permit as soon as possible, but no later than noon of the next working day, followed
by written notice to the Division addressing all of the criteria set forth in Part I1.E.1 of the
Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reps
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS Uncontrolled Controlled
Point Pollutant CAS # Emissions Emissions
(lb/yr) (lb/yr)
Benzene 71432 3,548 177
Toluene 108883 2,891 145
Ethylbenzene 100414 394 20
001 Xylenes 1330207 854 43
n-Hexane 110543 19,250 693
2,2,4-
540841 1,577 79
Trimethylpentane
Benzene 71432 828 41
03
n-Hexane 110543 2,602 130
Benzene 71432 27 1
04
n-Hexane 110543 237 12
Benzene 71432 296 15
012 Toluene 108883 296 15
n-Hexane 110543 1,258 63
015 Benzene 71432 290 15
Page 12 of 16
C40
, : COLORADO
__f Air Pollution Control Division
Department of Public Health Fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Toluene 108883 506 25
Ethylbenzene 100414 274 14
Xylenes 1330207 504 25
n-Hexane 110543 1,696 85
Benzene 71432 2,451 123
Toluene 108883 1,327 66
Ethylbenzene 100414 142 7
016 Xylenes 1330207 427 21
n-Hexane 110543 21,010 1,051
2,2,4-
540841 1,546 77
Trimethylpentane
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 001:
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
VOC 5.030 0.2515 EE LP Tanks
71432 Benzene 0.054 0.0027 Ef P Tanks
108883 Toluene 0.044 0.0022 EEtP Tanks
100414 Ethylbenzene 0.006 0.0003 Ef P Tanks
1330207 Xylene 0.013 0.0007 EQP Tanks
110543 n-Hexane 0.293 0.0147 EEtP Tanks
540841 2'2'4 0.024 0.0012 E&P Tanks
Trimethylpentane
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
Point 003:
Uncontrolled
CAS # Pollutant Emission Factors Source
lb/bbl
VOC 0.262 CDPHE
71432 Benzene 0.007 CDPHE
110543 n-Hexane 0.022 CDPHE
Page 13 of 16
C ,v, ....,.. COLORADO
Air Pollution Control Division
Department at Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
Point 004:
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
VOC 0.23600 0.01180 CDPHE
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
Point 012:
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/MMscf lb/MMscf
VOC 17175.3 858.8 All emission
71432 Benzene 56.3 2.8 factors are
108883 Toluene 56.4 2.8 based on the
displacement
equation and the
110543 n-Hexane 239.4 12.0 Pronghorn 11-
14-5HZ wet gas
analysis.
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.The displacement
equation can found in "EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10-
Displacement Equation(10.4-3) "
Point 015:
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/MMscf lb/MMscf
VOC 17586.3175 879.3159 Gas Analysis
71432 Benzene 55.2335 2.7617 Gas Analysis
108883 Toluene 96.2729 4.8137 Gas Analysis
100414 Ethylbenzene 52.1045 2.6052 Gas Analysis
1330207 Xylene 95.8051 4.7903 Gas Analysis
110543 n-Hexane 322.6634 16.1332 Gas Analysis
Point 016:
Uncontrolled Controlled
CAS # Pollutant Emission Emission Source
Factors Factors
lb/MMscf lb/MMscf
AP-42
CO (lb/MMBtu) 0.31 0.31 Chapter 13.5
VOC 93817.0 4690.9 ProMax
71432 Benzene 222.8 11.1 ProMax
108883 Toluene 120.6 6.0 ProMax
1330207 Xylene 38.8 1.9 ProMax
Page 14 of 16
C _ „,,,, .0.....-r. COLORADO
` Air Pollution Control Division
Department of Public Health&Envtronment
Dedicated to protecting and improving the health and environment of the people of Colorado
Uncontrolled Controlled
CAS # Pollutant Emission Emission Source
Factors Factors
lb/MMscf lb/MMscf
110543 n-Hexane 1910.0 95.5 ProMax
540841 2'2'4 140.5 7.0 ProMax
Trimethylpentane
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
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) Point 012, 015: This source is subject to 40 CFR, Part 60, Subpart 0000a - Standards of
Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or
Reconstruction Commenced after September 18, 2015 (See June 3, 2016 Federal Register posting
- effective August 2, 2016.) This rule has not yet been incorporated into Colorado Air Quality
Control Commission's Regulation No. 6. A copy of the complete subpart is available at the Office
of the Federal Register website
at: https://www.federalregister.gov/documents/2016/06/03/2016-11971/oil and natural gas
sector emission standards for new reconstructed and modified sources
9) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC, HAP
PSD Synthetic Minor Source of: VOC
NANSR Synthetic Minor Source of: VOC
MACT HH Area Source Requirements: Not Applicable
10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
Page 15 of 16
a •":'C COLORADO
m Air Pollution Control Division
Department of Public Health&Envtronment
Dedicated to protecting and improving the health and environment of the people of Colorado
NSPS 60.1-End Subpart A - Subpart UUUU
NSPS Part 60, Appendixes Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 16 of 16
Colorado 4'9 PenWttirP2 Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Elie Chavez
Package#: 431475
Received Date: 6/12/2020
Review Start Date: 10/22/2020
Section 01-Facility Information
Company Name: Bonanza Creek Energy Operating Company,LLC Quadrant Section Township Range
County AIRS ID: 123 NWNW 5 5N 61
Plant AIRS ID: 9892
Facility Name: Pronghorn 11-14-5HZ Production Facility
Physical
Address/Location:
County: Weld County
Type of Facility: Exploration&Production Well Pad
What industry segment?Oil&Natural Gas Production&Processing
Is this facility located in a NAAOS non-attainment area? Yes
If yes,for what pollutant? Ozone(NOx&VOC):.
Section 02-Emissions Units In Permit Application
Leave Blank-For Division Use Only
AIRs Point# Permit#
Emissions (Leave blank unless Issuance Self Cert Engineering
(Leave blank unless APCD Emissions Source Type Equipment Name Action
Control? APCD has already # Required? Remarks
has already assigned)
assigned)
Permit
001 Storage Tank CNDTK-01 Yes 12WE1828 5 No Modification
Permit
004 Liquid Loading L-01. Yes 12WE1828 5 No Modification
Permit
016 Separator Venting LPGFL Yes 12WE1828 5 No Modification
Section 03-Description of Project
This modification permits new throughput limits for the condensate storage tanks(AIRS 001)and high/low pressure separators(AIRS 016).Emissions for these points were
calculated using previously-permitted emission factors.This modification also permits new throughput limitiations and the use of state-default emission factors for the
condensate truck loadout(AIRS 004).In addition,the following changes were made to the construction permit:
1.Included Colorado Regulation No.7,Part D,Section I.K.for pneumatic pump requirements. It should be noted that the Section I.K.requirements did not exist at the time of
previous permit issuance on 4/18/2017.Although this modification request did not alter any permitted limitations for pneumatic pumps P-01(AIRS 012)or P-02(AIRS 015),these
pumps are subject to the requirements of Section I.K.,as noted in the permit application received 6/12/2020.As such,these applicable requirements were incorporated into this
issuance of the construction permit.
2.Included Colorado Regulation No.7,Part D,Section V.for facility-wide inventory requirements. It should be noted that the Section V.requirements did not exist at the time of
previous permit issuance on 4/18/2017.This facility is subject to the requirements of Section V.,as noted in the permit application received 6/12/2020.As such,these applicable
requirements were incorporated into this issuance of the construction permit.
3.Included emission factors for pneumatic pump P-01(AIRS 012).Although this modification request did not alter any permitted limitations for this pneumatic pump,the
emission factors established with the 2nd issuance of 12WE1828 are applicable and were therefore reincorporated into the construction.permit.
Sections 04,05&06-For Division Use Only
Section 04-Public Comment Requirements
Is Public Comment Required? Yes
If yes,why? Requesting Synthetic Minor Permit
Section 05-Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Colorado Air Permitting Project
Section 06-Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) 10000 ❑ ❑
Title V Operating Permits(OP) ❑ ❑ ❑ Q ❑ ❑ ❑ El
Non-Attainment New Source Review(NANSR) U U
Is this stationary source a major source? I No'7%,71
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) UULLIU U
Title V Operating Permits(OP) UULU U U U U
Non-Attainment New Source Review(NANSR) ❑ ❑
Section 01-Administrative Information
(Facility AIRs ID: '(1 ;.1111_._. '8882 DOI
County Plant Point
Section 02-Equipment Description Details
Storage Tank Liquid
Detailed Emissions Unit SiXIB14D'pd/((ffxed roof storage vesselsUsed to stole condensate', .
Description:
Emission Control Device Three(3)LEED 13-0010 ECDs(ECD 01-03) • •
Description:
Requested Overall VOC&HAP Control Efficiency N: 95.0
Limited Process Parameter atikat,
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Storage Tank(s)
Actual Throughput= .,S+k75fCO Barrels(bbl(per year
Requested Permit Limit Throughput= .. f4 ::84;700.44 Barrels(bbl)per year Requested Monthly Throughput= u-._ Barrels(bbl)per month I
Potential to Emit(PTE)Condensate Throughput= 60700.0 Barrels(bbl)per year
Secondary Emissions-Combustion Device(s)
•
Heat content of waste gas= • 7882.0 Btu/scf
Volume of waste gas emitted per BBL of liquids
produced= `42.2 scf/bbl
Actual heat content of waste gas routed to combustion device= 6 MMBTU per year
Requested heat content of waste gas routed to combustion device= ..•MMBTU per year
Potential to Emit(PTE)heat content of waste gas routed to combustion device= .-MMBTU per year
Control Device
Pilot Fuel Use Rate: s -'.$5,5 scfh MMscf/yr
Pilot Fuel Gas Heating Value: •2882 Btu/scf .. ._MMBTU/yr
Section 04-Emissions Factors&Methodologies
Will this storage tank emit flash emissions? 2.kilYtftift
Emission Factors Condensate Tank
Uncontrolled Controlled
Pollutant (lb/bbl) (Ib/bbl( Emission Factor Source
(Condensate (Condensate
Throughput) Throughput)
VOC 5.0300 J.25t5 Site Specific E.F.(includes flash)
Benzene 0.0540 0:.C:1 Site Specific E.F.(includes flash)
Toluene 0.0440 0)C22 Site Specific E.F.(includes flash)
Ethylbenzene 0.0060 C^003 Site Specific E.F.(mCludes flash)
_ Kylene 0.0130 03107 Site Specific E.F.(includes flash)
n-Hexane 0.2930 J5:47 Site Specific E.F.(includes flash)
224TMP 0:0240 O..;C1_> Ste Specific E-F.(includes flash) ..
Control Device
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source
(waste heat (Condensate
omhusted) Throughput)
PM10 0.0075 J.DL9 AP-42 Table 1.4-2(PM10/PM.23)
PM2.5 4,;.00974 0:CO9 .AP-42 Tahie1.4-2(PM10/PM.2.5)
SOx ,�E0 96s O.v4C1 AP-42 Table 1.4-2(50x)
NOx I Ntig:0.008D 00:03 AP-42 Chapter 13.5 Industrial Flares(NOx)
CO ID4414 a$N 0.0371 AP-42 Chapter 13.5 Industrial Flares(CO)
Pilot Light Emissions
' Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) (lb/MMsct) Emission Factor Source
(Pilot Gas Heat (Pilot Gas
Combusted( Throughput)
PM10 (00°0,0074 ="y' 21.473: AP-42 Table 14-2(PM10/PM.2.5)
PM2.5 I 2'150374 z.41y? AP-42 Table 1.4-2(PM10/PM.2.S)
SOx "r""0.0006 _6:353 AP 42 Tattle 1.4-2(00x)
NOx 0.0680 1356-c0 AP-42 Chapter 13.5 Industrial Flares(NOx)
VOC .0.0014 :5 5-19_' AP-42 Table 1.4-2(VOC)
CO 0,3100 3.i A:30 AP-42 Chapter 13.5 Industrial Flarei(CO)
Section 05-Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month)
PM10 00 CJ 0.0 0i ✓2 c9 •
PM2.5 0 0 ..-. c- _- ., ..
SOx -
NOx 0 3 ^.3 0.3 0.3 _3 132
VOC 155.2 :17 7 c 9 101 2 _. ...
CO 1.5 1.2 1.2 1.5 1.5 .•7
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(Ibs/year) (Ibs/year) (Ibs/Year) (lbs/year) (Ibs/year)
Benzene 394°8 2954 5 _4?4 3537 s 17, •
Toluene 280.8 241?3 20802 .2
Ethylbenzene 2942 151 0 L6.s s,=.
3 of 14 K:\PA\2012\12W E1828.CP5
Storage Tank(s)Emissions Inventory
Xylene 8541 711 8 35 6 8541 42 7 )
n Hexane 19250 1 -60..1 8 8621 19250 1 962 5
224TMP 15753 13140 637 1,768 788
1
L
I
4 of 14 K\PA\2012\12W E1828 CP5
f
Storage Tank(s)Emissions Inventory
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,B ....
Regulation 7,Part D,Section I.C,D,E,F
Regulation 7,Part D,Section 1.0,C
Regulation 7,Part D,Section II.B,C.1,C.3
Regulation 7,Part D,Section II.C.2
Regulation 7,Part D,Section II.C.4.a.(i)
Regulation 7,Part D,Section ll.C.4.a.(ii)
Regulation 6,Part A,NIPS Subpart Kb ..
Regulation6,Part A,NSPS Subpart OOOO j.c Tank a tat subject--"o N5P50O0G
NSPS Subpart OOOOa - `l-.0 to .Sr_. ...
Regulation 8,Part E,MACT Subpart HH
(See regulatory applicability worksheet for detailed analysis)
Section 07-Initial and Periodic Sampling and Testing Requirements
For condensate or crude oil tanks,does the company use the state default emissions factors to
estimate emissions? No _
If yes,are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or e quaff to 20 tons VOC per year OR are the 5,
uncontrolled actual or requested emissions fora condensate storage tank estimated to be greater than or equal to 80 tpy?
If yes,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
Does the company use a site specific emissions factor to estimate emissions? Yes '
If yes and if there are flash emissions,are the emissions factors based on a pressurized liquid sample drawn at the facility being
permitted(for produced water tanks,a pressurize liquid sample must be analyzed using flash liberation analys s)?This sample .�
should be considered representative which generally means site specific and collected within one year of the application
received date.However,if the facility has not been modified(e.g.,no new wells brought on-line),then it maybe appropriate to -s°_4
use an older site-specific sampletiriTare"
If no,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
Does the company request a control device efficiency greater than 95%for a flare or combustion device? _' �r
If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Section 08-Technical Analysis Notes
1.This modification requested a change in condensate throughput only.All emission factors used in this analysis were previously established in Issuance 4 of 12WE1828.These emission factors were based on
site-specific samples obtained 11/16/2012 for the Pronghom 11-14-5HZ well and 12/8/2014 for the K-5-SXRLNB well.Based on the data obtained from COGCC's COG'S database,no new wells have been brought
online since these samples were obtained,nor has any producing well been restimulated.As such,the previously established emission factors are still considered to be valid for this facility.
2.NOx and CO emissions from this source are below APEN reporting thresholds.Asa result,limits and emission factors are not included in the permit for NOx or CO.
3.It should be noted that an emission factor for VOC associated with pilot light combustion is not incorporated into the permit.This is due to the fact that the pilot light only results in a negligible contribution of
VOC(0.004 tpy).This minimal amount of emissions does not impact the total VOC limit for this source and therefore can be ignored.
4.Initial and periodic visible emissions checks for the control device are addressed by the O&M plan.Asa result,the permit does not contain initial or periodic opacity testing.
5.This facility is not yet subject to the storage tank measurement system requirements of Colorado Regulation No.7,Part D,Section II.C.4.These requirements apply to existing controlled storage tanks that are
modified after 5/1/2020 such that an additional condensate storage vessel is added.Pursuant to the APED received with the 6/12/2020 applications the date of last storage vessel installation was 2/2012.As
such,these condensate storage tanks are not subject to the provisions of Section II.C.4.
6.This facility is not subject to the storage vessel provisions of NIPS Kb as each vessel is less than`472 bbl in capacity.
7.This facility is not subject to the storage vessel provisions of NIPS 0000/a as potential VOC emissions,when considering enforceable controls in accordance with 560.5365(e)and§60.5365a(e),are less than 6
tons/year.
8.This facility is not subject to the storage vessel provisions of MACE HH as individual and total HAP emissions from this facility are below the 10 tons/year individual HAP and 25 tons/year total HAP major source
thresholds.Storage vessel requirements apply only to major sources of HAP.Because facility-wide HAP emissions at this facility are below the major source thresholds for HAP,this facility is not subject to the
storage vessel provisions of MACT HH.
•
Section 09-SCC Coding and Emissions Factors(For Inventory Use Only)
Uncontrolled
Emissions
AIRS Point 8 Process ft SCC Code Pollutant Factor Control%Units
01 4D4-802-31 Flond'Roof Tank,Cnne6ensate,woeklegtbreathieg+flashing losses PM30 lb/1,000 gallons Condensate throughput
PM2.5 - _. lb/1,000 gallons Condensate throughput
5Ox ... lb/1,000 gallons Condensate throughput
NOx __ _ lb/1,000 gallons Condensate throughput
• VOC ... _ lb/1,000 gallons Condensate throughput
CO lb/1,000 gallons Condensate throughput
Benzene ... lb/1,000 gallons Condensate throughput
Toluene .:. .- lb/1,000 gallons Condensate throughput
Ethylbenzene - _. lb/1,000 gallons Condensate throughput
Xylene lb/1,000 gallons Condensate throughput
n-Hexane _. lb/1,000 gallons Condensate throughput
224 TMP lb/1,000 gallons Condensate throughput
5 of 14 K:\PA\2012\12WE1828.CP5
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and B-APEN and Permit Requirements
Source is in the Non-Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section II.D.1.a)?
Is the construction date(service date)prior to 12/30/2002 and not modified after 12/31/2002(See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional gi
2. grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3,Part B,Section II.D.3)?
'You have indicated that source is in the Non•Attainment Area
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3,Part A,Section II.D.1.a)?
Is the construction date(service date)prior to 12/30/2002 and not modified after 12/31/2002(See PS Memo 05-01 Definitions 1.12 andl.14 and Section 2 for additional gi
2. grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3,Part B,Section II.D.2)?
'Source requires a permit
Colorado Regulation 7,Part D,Section I.C-F&G
1. Is this storage tank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area(Regulation 7,Part D,Section I.A.1)?
2. Is this storage tank located at oil and gas operations that collect,store,or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural I
3. Is this storage tank located at a natural gas processing plant(Regulation 7,Part D,Section I.G)?
4. Does this storage tank contain condensate?
5. Does this storage tank exhibit"Flash"(e.g.storing non-stabilized liquids)emissions-(Regulation 7,part D,Section I.G.2)?
6. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year VOC(Regulation 7,Part D,Section I.D.3.a(ii))?
an 7,Part 0,Section I.C-F
Part D,Section I.C.1 —General Requirements for Air Pollution Control Equipment—Prevention of Leakage
Part 0,Section I.C.2—Emission Estimation Procedures
Part D,Section I.D—Emissions Control Requirements
Part D,Section I.E—Monitoring
Part D,Section I.F—Recordkeeping and Reporting
Storage Tank is not subject to Regulation 7,Section 1.6
Part 0,Section I.G.2-Emissions Control Requirements
Part 0,Section I.C.l.a and b —General Requirements for Air Pollution Control Equipment—Prevention of Leakage
Colorado Regulation 7,Part D,Section II
1. Is this storage tank located at a transmission/storage facility?
2. Is this storage tank'located at an oil and gas exploration and production operation ,well production facilityz,natural gas compressor station'or natural gas processing ph
3. Does this storage tank have a fixed roof(Regulation 7,Part D,Section II.A.20)?
4. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year VOC(Regulation 7,Part D,Section II.C.1.c)?
sec.ro. _ al,Se_ C.3
Part 0,Section II.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Part D,Section II.C.1-Emissions Control and Monitoring Provisions
Part D,Section II.C.3-Recordkeeping Requirements
5. Does the storage tank contain only"stabilized"liquids(Regulation 7,Part D,Section II.C.2.b)?
Storage tank is suk , _ ,,Part D,Section II.C.2
Part D,Section II.C.2-Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
Is the controlled storage tank located at a well production facility,natural gas compressor station,or natural gas processing plant constructed on or after May 1,2020 or lc
6. facility that was modified on cr after May 1,2020,such that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydri
Storage Tans non 7,Part 0,Section il.C.4.a(i,
Is the'controlled storage tank located at a well production facility,natural gas compressor station,or natural gas processing plant constructed on or afterJanuary 1,2021
7. a facility that was modified on or after January 1,2021,such that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of
,storage Tank is no. laect to Regulation 7,Part 0,Section li.C.4.a(ii),b-f
40 CFR,Part 60,Subpart Kb,Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters(m 5)[-472 BBLs](40 CFR 60.110b(a))?
2. Does the storage vessel meet the following exemption in 60.111b(d)(4)?
a. Does the vessel has a design capacity less than or equal to 1,589.874 m'["'10,000 BBL]used for petroleum'or condensate stored,processed,or treated prior t
3. Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)after July 23,1984(40 CFR 60.110b(a))?
4. Does the tank meet the definition of"storage vessel"3 in 60.111b?
5. Does the storage vessel store a"volatile organic liquid(VOL)"5 as defined in 60.111b?
6. Does the storage vessel meet any one of the following additional exemptions:
a.Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa["'29.7 psi]and without emissions to the atmosphere(60.110b(d)(2))?;or
b.The design capacity is greater than or equal to 151 ma
[ 950 BBL]and stores a liquid with a maximum true vapor pressure 6 less than 3.5 kPa(60.110b(b))?;or
c.The design capacity is greater than or equal to 75 M3['"472 BBL]but less than 151 m3[-950 BBL]and stores a liquid with a maximum true vapor pressure 6 less
7. Does the storage tank meet either one of the following exemptions from control requirements:
a.The design capacity is greater than or equal to 151 m3(-950 BBL]and stores a liquid with a maximum true vapor pressure greater than or equal'to 3.5 kPa but I
b.The design capacity is greater than or equal to 75 M 3[ 472 BBL]but less than 151 m3['-950 BBL]and stores a liquid with a maximum true vapor pressure great.
Storage Tani;is not subject to NSPS Kb
40 CFR,Part 60,Subpart 0000/0000a,Standards of Performance for Crude Oil and Natural Gas Production,Transmission and Distribution
Is this storage vessel located at a facility in the onshore oil and natural gas production segment,natural gas processing segment or natural gas transmission and storage sel•
1. industry?
2. Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)between August 23,2011 and September 18,2015?
3. Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)after September 18,2015?
4. Are potential VOC emissions'from the individual storage vessel greater than or equal to 6 tons per year?
5. Does this storage vessel meet the definition of"storage vessel"'per 60.5430/60.5430a?
6.,Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH?
'Storage Tank is not subject to RSPS OOOO
[Note: If a storage vessel is previously determined to be subject to NSPS OOOO/OOOOa due to emissions above 6 tons per year VOC on the applicability determination
should remain subject to NSPS OOOO/OOOOa per 60.5365(e)(2)/60.5365a(e)(2)even if potential VOC emissions drop below 6 tons per year]
40 CFR,Part 63,Subpart MACT HH,Oil and Gas Production Facilities
1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria:
a.A facility that processes,upgrades or stores hydrocarbon liquids'(63.760(a((2));OR
A facility that processes,upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category
b.delivered to a final end user'(63.760(a)(3)(?
2. Is the tank located at a facility that is major'for HAPs?
3. Does the tank meet the definition of"storage vessel"'in 63.761?
4. Does the tank meet the definition of"storage vessel with the potential for flash emissions"s per 63.761?
5. Is the tank subject to control requirements under 40 CFR Part 60,Subpart Kb or Subpart OOOO?
'Storage Tank is not subject to MACT iH
Subpart A,General provisions per§63.764(a)Table 2
§63.766-Emissions Control Standards
§63.773-Monitoring
§63.774-Recordkeeping
§63.775-Reporting
RACT Review
RACT review is required if Regulation 7 does not apply AND if the tank is in the non-attainment area. If the tank meets both criteria,then review RACT requirements.
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Q,
Commission regulations.This document is not a rule or regulation,and the analysis it contains may not apply to a particular situation based upon t I
facts and circumstances. This document does not change or substitute for any law,regulation,or any other legally binding requirement and is not I
enforceable.In the event of any conflict between the language of this document and the language of the Clean Air Act„its implementing regulation
Quality Control Commission regulations,the language of the statute or regulation will control. The use of non-mandatory language such as"retort
"may,""should,"and"can,"is intended to describe APCD interpretations and recommendations.Mandatory terminology such as"must"and"requir
intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations,but this documi
Hydrocarbon Loadout Emissions inventory
Section 01-Administrative Information
(Facility Allis ID: - 123 9892 ::004
County Plant Point
Section 02-Equipment Description Details
Detailed Emissions Unit Truck loadout of condensate by submerged fill using vapor balance
Description:
Emission Control Device
Three(3)LEED 13-0010 ECDs.(ECD 01-03)
Description(
Is this load out controlled?
Requested Overall VOC&HAP Control Efficiency 51 95
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Hydrocarbon Loadout
Actual Volume Loaded= 65,700 Barrels(bbl)per year
Requested Permit Limit Throughput= 65,700 Barrels(bbl)per year Requested MonthlyThroughput= _.. Barrels(bbl)per month
Potential to Emit(PTE)Volume Loaded= .;65,700:Barrels(bbl)per year
Secondary Emissions-Combustion Device(s)
Heat content of waste gas= 2204 Btu/scf
Gas to Oil Ratio= 1.79 scf/bbl
Actual Volume of waste gas emitted per year= _scf/year
Requested Volume of waste gas emitted per year= scf/year
Actual heat content of waste gas routed to combustion device= MMBTU per year
Requested heat content of waste gas routed to combustion device= _. MMBTU per year
Potential to Emit(PTE)heat content of waste gas routed to combustion device= _ MMBTU per year
Control Device
Pilot Fuel Use Rate: scfh MMscf/yr Pilot combustion accounted for at condensate storage tanks(Point 001)
Pilot Fuel Gas Heating Value: ;Btu/scf • MMBTU/yr
Section 04-Emissions Factors&Methodologies
Does the company use the state default emissions factors to estimate emissions? Yes „
Does the hydrocarbon liquid loading operation utilize submerged All? Yes ' ;se-4 to eatimate baussio s.
I �
Emission Factors Hydrocarbon Loadout
Uncontrolled Controlled
Pollutant (lb/bbl) (lb/bbl) Emission Factor Source
(Volume Loaded) (Volume Loaded)
VOC _. _ __ CondeVlsate Lfradoutstate E F
Benzene -,� _ Cnnd sate toadou£5tate E.Ri
Toluene Conde sate tcaadoutl teEF
Ethylbenzene _ • __ Cond0i6atefo daut'State EF"'
Xylene Cond6isateL4adout ateEF
n-Hexane Candkfluate Ldadaut State E F.
224 IMP _ _...._ CondHtsatnLaddhatatate
Control Device
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source
(waste heat combusted) (Volume Loaded)
PM1D D.0075 AP-421abfela-z)PMiq/PMrt24)
PM2.5 0.0071 _ AP-4Z ablei, i(P 0/PMi&j M
. . <
Sox 0.0006 - /[P-4 able 142(SOx} �,-
Non 0.7680 _, AP-42apterv_1t5 lndthstnaf afes(Rs•01 rFA4
CO 0.3100 .__ AP-416206;13.S Ind₹ostrlat FCares(CO(
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (Ib/MMscf) Emission Factor Source
(Pilot Gas
(Waste Heat Combusted) Throughput)
PM10
PM2.5 ,._ '
5Ox
NOx
VOC
CO
8 of 14 K:\PA\2012\12WE1828.CPS
Hydrocarbt; ,/e t
Section 05-Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month)
PM10
PM2.5
SOx _.__ _..
NOx
VOC
CO
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(Ibs/year) (lbs/year) (Ibs/year) (Ibs/Year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n-Hex _
224 TMP
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,B
Regulation 7 Part D Section II.C.5.
(See regulatory applicability worksheet for detailed analysis)
Section 07-Initial and Periodic Sampling and Testing Requirements
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
1.The heat content used in this application was obtained from a site-specific sample analyzed in 2014,as noted in operator correspondence received 11/3/2020.Based on the data obtained from COGCC's COG'S database,no new wells have been
brought online since this sample was obtained,nor has any producing well been-restimolated.As such,this heat content was considered to be acceptable for the purposes of this application.
2.Note that pilot gas emissions from the3 combustors are calculated with the condensate tank point(AIRS 001).
3.NOx and CO emissions from this source are below APES reporting thresholds.As a result,limits and emission factors are not included in the permit for NOx or CO.
4.No HAP associated with this unit is above APEN reporting thresholds.Asa result,HAP emission factors were not included in the permit.
5.Initial and periodic visible emissions checks for the control device are addressed by the O&M plan.Asa result,the permit does not contain initial or periodic opacity testing.
6.This source is subject to the hydrocarbon liquid loading requirements of Colorado Regulation No.7,Part 0,Section ll.C 5.,as liquid loadout at this facility exceeds 5,000 bbl/year.These requirements were therefore included in the construction permit.
Note that the compliance date for this facility is 5/1/2021.
Section 09-SCC Coding and Emissions Factors(For Inventory Use Only)
Uncontrolled
Emissions
AIRS Point# Process# SCC Code Pollutant Factor Control% Units
004 Ui .. .. PM10 lb/1,000 gallons transferred
PM2.5 _,_ lb/1,000 gallons transferred
SOx lb/1,000 gallons transferred
NOx __. lb/1,000 gallons transferred
VOC lb/1,000 gallons transferred
CO .. Ih/1,000 gallons transferred
Benzene _ _ Ili/1,000 gallons transferred
Toluene -. Ili/1,000 gallons transferred
Ethylbenzene lb/1,000 gallons transferred
Xylene .. lb/1,000 gallons transferred
n-Hexane _.. .. lb/1,000 gallons transferred
224 TMP lb/1,000 gallons transferred
9 of 14 K:\PA\2012\12WE1828.CP5
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
Source is in the Non-Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section II.D.1.a(?
2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part B,Section 11.0.1.1)?
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 5TPY,NOx greater than 10TPY or CO emissions greater than 10TPY(Regulation3,Part B,Section 11.0.3)?
. ; _in the Non-Attainment Area
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY(Regulation 3,Part A,Section II.D.1.a)?
2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part B,Section 11.0.1.1)?
3. Is the loadout operation loading less than 10,000 gallons(238 BBLs(of crude oil per day on an anneal 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 11.0.2)?
'Source requfr-.s ....
Colorado Regulation 7 Part D Section II.C.5.
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?
I'•.' -`sdrocarbon liquids loadout source is subject to Regulation 7 Part 0 Section
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 I I.C.5.a.(iv)-Loadout observations and Operator Training
Section II.C.5.a.(v)-Records
Section II.C.S.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,
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 orsubstitute for
regulation,or any other legally binding requirement and is notlegally enforceable.In the event of any conflict between the language of this document and the language of the Clean Air Act„it:
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,"
intended to describe APCD interpretations and recommendations.Mandatory terminology such as'must"and"required"are intended to describe controlling requirements under the terms of tl
Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself.
Separator Venting Emissions Inventory
Section 01-Administrative Information - -
'Facility AIRs ID: 123 9892 016
County Plant Point
Section 02-Equipment Description Details
Two(2)high/low pressure(HLP)separators
Detailed Emissions Unit Description:
Three(3)LEED 13-0010 ECDs(ECD 01-03)
Emission Control Device Description:
Requested Overall VOC&HAP Control Efficiency%: - 95
Limited Process Parameter t 6L0eR
Gas meter ° ear rsuryStafl'ec, do'pei°atldnsl`
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Separator
Actual Throughput= 11.0 MMscf per year
Requested Permit Limit Throughput= 11.0 MMscf per year Requested Monthly Throughput= MMscf per month
Potential to Emit(PTE)Throughput= __.- MMscf per year
Secondary Emissions-Combustion Device(s)for Air Pollution Control
Separator Gas Heating Value: 2470.0 Btu/scf
Volume of waste gas emitted per BBL of
liquids throughput: 'scf/bbl
Control Device I 1
Pilot Fuel Use Rate: scfh -MMscf/yr Pilot combustion accounted for at condensate storage tanks(Point 001)
Pilot Fuel Gas Heating Value: Btu/scf
Section 04-Emissions Factors&Methodologies
Description
Two(2)wells at this facility flow Into two(2)high/low pressure(HIP)separators.The high pressure gas from the high pressure side of the HLP separators is routed to the sales line.The low pressure gas from the low
pressure side of the HLP separators is routed to three(3)enclosed combustors.The requested modification involves altering the throughput limit only.The site-specific emisisoo factors used in this Preliminary Analysis
were obtained from the previous Issuance of 12WE1828.
MW I> 42.3 Ib/Ib-mol Displacement Equation
Ex=Q*MW*Xx/C
Weight%
Helium ::0.0
CO2 1.7
N2 ...:1.1.9
methane 5.3
ethane 10.8
propane 29.7
isobutane 6.2
n-butane 23.0
isopentane 6.0
n-pentane 7.5
cyclopentane 0.7
n-Hexane 1.6
cyclohexane i.0.3
Other hexanes 2.6
heptanes :1.2
methylcyclohexane ...5:0.2
224-TMP 8.1
Benzene 0.2
Toluene 0.1
Ethylbenzene -0.0
Xylenes 00
C6*Heavies 0.8
Total
VOC Wt%
11 of 14 K:\PA\2012\12WE1828.CP5
Separator Venting Emissions inventory
Emission Factors Separator Venting
Uncontrolled Controlled
Emission Factor Source
Pollutant (Ib/MMscf) (Ib/MMscf)
(Gas Throughput) (Gas Throughput)
VOC __ Extended gasanafysls Manually entered previously permitted EF
Benzene .,.. . -_ _-Extended gasufl(ysIs -rf-, Manually entered previously permitted EF
Toluene __ _ `Extended gas a aiysts 2,,,-,- Manually entered previously permitted EF
Ethylbenzene _ mended gas arpa(ys(s - Manually entered previously permitted EF
Xylene _, Intended gas dpo)ys(s Manually entered preciously permitted OF
Xylene duteyded gasanalys(s yr '-Manually entered previously permitted EF
n-Hexane _ ._ .. tended gas analysis ' - Manually entered previously permitted EF
224 TMP _ .. _ x "}}ended gauaaalysis 4 -.Manually entered previously permitted EF
Primary Control Device
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) Ib/MMscf Emission Factor Source
(Waste Heat
Combusted) (Gas Throughput)
PM10 0.0075 ,_. AP-42 Table 1.4-2(PM1G/PM.2.S)
PM2.5 0.0075 AP 4ZT ble 1.4-2 PME0/PM.2.5)
500 0.0006 -- ''.---,-5;
- t :'AC,42 Table 14.-2.(5Ox)
NOx 0.0680 _ A" AP 42 Chapter 13.5 lndust[0al Flares(NOn)-
CO 0.3100 ___ ti„.AP-42'Cbapter13.5 Industrial Flares(CO),
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) Ib/MMscf Emission Factor Source
(Waste Heat
Combusted) (Pilot Gas Throughput)
PM10
PM2.5 _ `- "__
SOx
NOx -
VOC
CO .__
Section 05-Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (Ins/month)
PM10 _-_ ._ _-_
PM2.5 _ _- .
SOx
NOx __ ..„, _
VOC _ _
CO '-'
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (Ibs/year) (Ibs/year( (Ibs/year( (16s/year) - -
Benzene - .22
Toluene ___: _ 2,- _
Ethylbenzene _ _ _,_
Xylene „*.. - _.. _ __
n-Hexane �___ ____- ___,
224 TMP ...
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,B
Regulation 7,Part D,Section II.B,F
Regulation 7,Part D,Section 11.8.2.e
(See regulatory applicability worksheet for detailed analysis)
12 of 14 K:\PA\2012\12WE1828.CP5
Separator Venting Emissions inventc,ry
Section 07-Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Does the company use site specific emission factors based on a gas sample to estimate emissions?This sample should represent the gas outlet of the equipment covered under this AIRs ID,and should have been collected within one year of the application received date.However,if the facility has
not been modified(e.g.,no new wells brought on-line),then it may be appropriate to use an older site-specific sample.
If no,the permit will contain an"Initial Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate
that the emission factors are less than or equal to the emissions factors established with this application.
•
Are facility-wide permitted emissions of VOC greater than or equal to 40 tons per year in the ozone nonattainment
area OR are emissions greater than or equal to 90 tons per year in the ozone attainment area? +7ks E r
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
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.
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
n a �1 a#� / Y 4 /
qq - O -
al
s - r F' bit "% 1.g;f
'�v'�;°!JA`fi�.'3/ �r .r5' •r�rim3bA�!'✓r<a,;ate" .aa�:,.D'"mn rn.,--b8zi°skl rr�6'J'f,"'.55Le
Section 08-Technical Analysis Notes
1.This modification requested a change in separator gas venting throughput only.Emission factors used in this analysis for NOx,CO,VOC and all HAP were previously established in Issuance 4 of 12WE1828.These emission factors were
manually entered into the PA as they were previously approved,and were not recalculated with this permit modification.It should be noted that these emission factors were based on site-specific samples obtained on 10/24/2016.Based
on the data obtained from COGCC'sCOGIS database,no new wells have been brought online since these samples were obtained,nor has any producing well been restimulated.As such,the previously established emission factors are still
considered to be valid for this facility.
2.Total permitted emissions from this facility are<40 tons/year VOC.As such,initial and periodic extended gas analyses are not required.
3.Note that pilot gas emissions from the 3 combustors are calculated with the condensate tank point(AIRS 001).
4.NOx emissions from this source are below APEN reporting thresholds.As a result,limits and emission factors are not included in the permit for NOx.
5.Benzene,toluene,xylene,n-Hexane and 2,2,4-Trimethylpentane are the only reportable HAPs for this unit.As a result,they are the only HAPs for which emission factors are included in the permit.
6.Removed initial compliance requirement to install a flowmeter(Previous Condition 5 of 12WE1828).This flowmeter was installed and continues to operate in the field As such,this one-time requirement has been met and it was
therefore removed from the construction permit.Note that final approval for issuance 4 of this permit was granted on 10/20/2017.
7.Included requirement to calibrate and maintain the flowmeter installed per manufacturer specifications,pursuant to the most.current Division-standard language for construction permits.
8.Initial and periodic visible emissions checks for the control device are addressed by the O&M plan.As a result,the permit does not contain initial or periodic opacity testing.
9.This source is subject to the Colorado Regulation No.7,Part D,Section II.F.control of emissions from well production facilities,as the Pronhorn K-5-8XRLNB well began production after the 8/1/2014 applicability date of this rule.This was
confirmed in operator correspondence received 11/3/2020.
10.Note that the process description included in the 6/12/2020 permit modification application listed three(3)heated separators In operator correspondence received 11/3/2020,it was clarified that there are two(2)high/low pressure
(HLP)separators into which the wells produce,which are covered by this Point 016.The third heated separator onsite is a liquids knockout vessel installed prior to the compressor.This vessel routes gas exclusivelyto the compressor and is
not a source of emissions.It is not covered under this Point 016.
Section 09-SCC Coding and Emissions Factors(For Inventory Use Only)
AIRS Point# Process 6 SCC Code Pollutant Uncontrolled Emissions Factor Control% Units
016 01 _ PM10
PM2.5
Sox ?.5
NOx -.:.
VOC
CO
Benzene 222.0 95
Toluene 1200.6 95
Ethylbenzene 2.2.9 95
Xylene 38.0 _.. ...,_.
n-Hexane 1910.0 95 lbfMavt5 h-
. 224 TMP 140.5 95 It/dsMa F
13 of 14 K:\PA\2012\12WE1828.CP5
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
rce is in the Non-Attainment Aa
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 I
IYou have indicated that source is in the Non-Attainment Area
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3,Part A,Section II.D.1.a)?
2. 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
ISeu.'
Colorado Regulation 7,Part D,Section II •
1. Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014?
•,-ce is subject to Regulation 7,Part O,Section 11.8.2,F
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%
`ot enough information
Section II.B.2.e—Alternative emissions control equipment
Disclaimer
and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may nc
particular situation based upon the individual facts and circumstances. This document does not change or substitute for any h
or any other legally binding requirement and is not legally enforceable.In the event of any conflict between the language of th
and the language of the Clean Air Act„its implementing regulations,and Air Quality Control Commission regulations, the lane
statute or regulation will control. The use of non-mandatory language such as"recommend,""may,""should,"and"can,"is int
describe APCD interpretations and recommendations. Mandatory terminology such as"must"and"required"are intended to c
controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations,but this documi
Condensate Storage Tank(s) APEN.
Cit4�, Form APCD-205
CDPHE Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment
for a new filing fee.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source(e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General
APEN (Form APCD-2OO) is available if the specialty APEN options will not satisfy your reporting needs.A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website.
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 12WE1828 AIRS ID Number: 123 / 9892 /001
Section 1 -Administrative Information
Company Name1: Bonanza Creek Energy Operating Company, LLC
Site Name: Pronghorn 11-14-5HZ Production Facility(COGCC#427089)
Site Location: Site Location
NWNW Sec 5, T5N, R61W County: Weld
40.43678, -104.24139
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip Code) 410 17th Street, Suite 1400
Denver, CO 80202 Contact Person: Alisson Soehner
Phone Number: (303) 803-1752
E-Mail Address2: asoehner@bonanzacrk.com
1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD.Any changes will require additional paperwork.
2 Permits,exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
432353
COLORADO
1 =77::=,
Permit Number: 12WE1828 AIRS ID Number: 123 /9892/001
Section 2 - Requested Action
❑ NEW permit OR newly-reported emission source
O Request coverage under traditional construction permit
❑ Request coverage under a General Permit
O GP01 O GP08
If General Permit coverage is requested, the General Permit registration fee of$312.50 must be
submitted along with the APEN filing fee.
-OR-
0 MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment O Change company name3
0 Change permit limit O Transfer of ownership4 ❑ Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info a Notes: Requesting updated throughput and emission limits based on previously
established emission factors.
3 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted.
Section 3 - General Information
General description of equipment and purpose: Condensate tank battery used to store condensate.
Company equipment Identification No. (optional): CNDTK-01
For existing sources, operation began on: 4/15/2012
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
Storage tank(s) located at: El Exploration Et Production (E&P)site O Midstream or Downstream (non E&P)site
Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ❑ No
Are Flash Emissions anticipated from these storage tanks? 0 Yes ❑ No
Is the actual annual average hydrocarbon liquid throughput≥ 500 bbl/day? O Yes 0 No
If"yes", identify the stock tank gas-to-oil ratio: m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) O Yes EI No
805 series rules?If so, submit Form APCD-105.
Are you requesting≥6 ton/yr VOC emissions(per storage tank), or are uncontrolled actual ❑ Yes 0 No
emissions≥6 ton/yr(per storage tank)?
COLORADO
Permit Number: 12WE1828 AIRS ID Number: 123 /9892/001
Section 4 - Storage Tank(s) Information
Actual Annual Amount Requested Annual Permit Limits
(bbl/year) (bbl/year)
Condensate Throughput: 54,750 65,700
From what year is the actual uocuut amount? 2019
Average API gravity of sales oil: 37.6 degrees RVP of sales oil: 8.1
Tank design: El Fixed roof ❑Internal floating roof ❑External floating roof
Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First
Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production
(bbl) Storage Tank(month/year) (month/year)
CNDTK-01 Six(6)400 bbls 2,400 2/2012 3/2012
Wells Serviced by this Storage Tank or Tank Battery°(E&P Sites Only)
API Number Name of Well Newly Reported Well
EJC per 05 - 123 - 34860 Pronghorn 11-14-5HZ ❑
email rec'd OS -®- 40087 'Pronghorn K-5-8XRLNB I 0
11/4/2020O
❑
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable,and should consider
future process growth. Requested values are required on all APENs,including APEN updates.
6 The EEO Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.43678,-104.24139
❑Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Operator Stack Discharge Height Above Temp. Flow Rate Velocity
ID No. Ground Level(Feet) (°F) (ACFM) (ft/sec)
ECD 01-03 25 500 N/A N/A
Indicate the direction of the stack outlet: (check one)
Q Upward 0 Downward D Upward with obstructing raincap
❑Horizontal 0 Other(describe):
Indicate the stack opening and size: (check one)
Q Circular Interior stack diameter(inches): 48
❑Square/rectangle Interior stack width(inches): Interior stack depth(inches):
❑Other(describe):
COLORADO
e[n.r ment
Permit Number: 12WE 1828 AIRS ID Number: 123 /9892/001
Section 6 - Control Device Information
O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
Vapor Size: Make/Model:
O Recovery
Unit (VRU): Requested Control Efficiency:
VRU Downtime or Bypassed(emissions vented):
Pollutants Controlled: VOC, HAPs
Rating: 1.07 MMBtu/hr
Type: Enclosed Combustor Make/Model: Three(3)LEED L3-0010 ECDs
❑ Combustion Requested Control Efficiency: 95 %
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: 500 Waste Gas Heat Content: 2,882 Btu/scf
Constant Pilot Light: ✓❑ Yes ❑ No Pilot Burner Rating: 0.16 MMBtu/hr
Description of the closed loop system:
O Closed Loop System
Pollutants Controlled:
O Other: Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (EftP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? -50 psig
Describe the separation process between the well and the storage tanks:
Gas, oil, and water are processed through the high/low pressure separators where oil and water are separated.
Oil is sent to the condensate tank battery storage on site.
COLORADO
Permit Number: 12WE1828 AIRS ID Number: 123 /9892/001
•
Section 8 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? 0 Yes ❑ No
If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Collection Efficiency Control Efficiency
Pollutant Control Equipment Description (%of total emissions captured (%reduction of captured
by control equipment) emissions)
VOC ECD 100 95
NOx
CO
HAPs ECD 100 95
Other:
From what year is the following reported actual annual emissions data? 201 9
Use the following table to report the criteria pollutant emissions from source:
Emission Factor? Actual Annual Emissions Requested Annual Permit
Emission Limit(s)5
Pollutant Source Uncontrolled Controlled Uncontrolled Controlled
Uncontrolled Units (AP-42, Emissions Emissions8 Emissions Emissions
Basis Mfg.,etc.) (tons/year)
(tons/year) (tons/year) (tons/year)
VOC 5.03 lb/bbl Permit 14 137.83 6.90 165.40 8.28
NO 0 068 lb/MMBtu AP•42 0.28 0.28 0.32 0 32
CO 0.310 IbIMMBtu AP-42 1.25 1.25 1 46 1.46
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable,and should consider
future process growth. Requested values are required on all APENs,including APEN updates.
7 Attach condensate liquid laboratory analysis,stack test results,and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide
projected emissions.
Section 9 - Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteriaEj Yes ❑No
pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year?
If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source:
Chemical Emission Factors Actual Annual Emissions
Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled
Service(CAS) Basis Units (AP-42, Emissions Emissions8
Number Mfg.,etc.) (lbs/year) (Ibs/year)
Benzene 71432 0.054 lb/bbl Permit 14 2.967 150
Toluene 108883 0.044 lb/bbl Permit 14 2,387 120
Ethylbenzene 100414 0.006 lb/bbl Permit 14 329 18
Xylene 1330207 0.013 __ Ib/bbl — Permit 14 723 38
n-Hexane 110543 0 293 lb/bbl Permit 14 16,058 804
2,2,4-Trimethylpentane 540841 0.024 lb/bbl Permit 14 1.325 68
7 Attach condensate liquid laboratory analysis,stack test results,and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide
projected emissions.
COLORADO
N<D I .6 Enn+onment
Permit Number: 12WE1828 AIRS ID Number: 123 /9892/001
•
Section 10 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
;41:3)/1 jf ���„ 6/8/2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
Alisson Soehner Environmental Engineer,Air Quality
Name(print) Title
Check the appropriate box to request a copy of the:
1:1 Draft permit prior to issuance
El Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit For more information or assistance call:
registration fee of$312.50, if applicable, to:
Small Business Assistance Program
Colorado Department of Public Health and Environment (303)692-3175
Air Pollution Control Division OR
APCD-SS-B1 (303)692-3148
4300 Cherry Creek Drive South
Denver, CO 80246-1530 APCD Main Phone Number
(303)692-3150
Make check payable to:
Colorado Department of Public Health and Environment
COLORADO
6
Nn 1+6 Fv�mnmrc�.
11/4/2020 State.co.us Executive Branch Mail-Bonanza Pronghorn 11-14-5HZ Application Questions
STATE OF Chavez-CDPHE, Elie<elie.chavez@state.co.us>
` )¢ COLORADO
Bonanza Pronghorn 11-14-5HZ Application Questions
Alisson Soehner<ASoehner@bonanzacrk.com> Wed, Nov 4, 2020 at 11:41 AM
To: "Chavez-CDPHE, Elie" <elie.chavez@state.co.us>, Patrick Dilsaver<pdilsaver@sIrconsulting.com>
Thanks Elie—the redline looks good to me!
Alisson
[Quoted text hidden]
https://mail.google.com/mail/u/0?ik=85031 f40e8&view=pt&search=all&permmsgid=msg-f%3A1682456212766043287&simpl=msg-f%3A16824562127... 1/1
Hydrocarbon Liquid Loading APEN
44,1; .. Form APCD-208
CDPHE Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment
for a new filing fee.
This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category,
there may be a more specific APEN for your source(e.g. amine sweetening unit, glycol dehydration unit,
condensate storage tanks, etc.). In addition, the General APEN (Form APCD-2OO)is available if the specialty APEN
options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution
Control Division(APCD)website.
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 12WE1828 AIRS ID Number: 123 / 9892 /004
Section 1 - Administrative Information
Company Name: Bonanza Creek Energy Operating Company, LLC
Site Name: Pronghorn 11-14-5HZ Production Facility(COGCC#427089)
Site Location
Site Location:
NWNW Sec 5, T5N, R61W County: Weld
40.43678, -104.24139
NAICS or SIC Code: 1311
Mailing Address:
(include Zip Cade) 410 17th Street, Suite 1400
Denver, CO 80202 Contact Person: Alisson Soehner
Phone Number: (303) 803-1752
E-Mail Address2: asoehner@bonanzacrk.com
1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD.Any changes will require additional paperwork.
2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
432354
COLORADO
Etrorrooment
t n�., emwawr
Permit Number: 12WE1828 AIRS ID Number: 123 /9892/004
Section 2 - Requested Action
O NEW permit OR newly-reported emission source
0 Request coverage under construction permit 0 Request coverage under General Permit GP07
If General Permit coverage is requested, the General Permit registration fee of$312.50 must be
submitted along with the APEN filing fee.
-OR-
❑✓ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment 0 Change company name3
El Change permit limit 0 Transfer of ownership' 0 Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
❑ Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info E Notes: Requesting updated throughput and emission limits based on state factors.
3 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted.
4 For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted.
Section 3 - General Information
General description of equipment and purpose: Loadout to tank truck of produced condensate
Company equipment Identification No. (optional): L-01
For existing sources, operation began on: 03/01/2012
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area? 0 Yes 0 No
Is this equipment located at a stationary source that is considered a Major Source of(HAP) 0 Yes 0 No
emissions?
Does this source load gasoline into transport vehicles? 0 Yes 0 No
Is this source located at an oil and gas exploration and production site? 0 Yes ❑ No
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annualEl Yes 0 No
average?
Does this source splash fill less than 6,750 bbl of condensate per year? 0 Yes 0 No
Does this source submerge fill less than 16,308 bbl of condensate per year? ❑ Yes ❑✓ No
470 COLORADO
2 =`,;7,17."`"`f.
Permit Number: 12WE1828 AIRS ID Number: 123 /9892/004
Section 4 - Process Equipment Information
Product Loaded: p Condensate ❑ Crude Oil 0 Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loaded5: 65,700 bbl/year Actual Volume Loaded: 65,700 bbl/year
This product is loaded from tanks at this facility into: Tank trucks
(e.g. "rail tank cars"or"tank trucks")
If site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor: Average temperature of F
bulk liquid loading:
Molecular weight of
True Vapor Pressure: Psia ®60 -F lb/lb-mol
displaced vapors:
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Loaded5: N/A bbl/year Actual Volume Loaded: NSA bbl/year
Product Density: lb/ft3
Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable,and should consider
future process growth. Requested values are required on all APENs,including APEN updates.
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.43678/-104.24139
0 Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this-section may remain blank.
Operator Discharge Height Above Temp. Flow Rate Velocity
Stack ID No. Ground Level(Feet) ('F) (ACFM) (ft/sec)
ECD 01-03 25 500 N/A N/A
Indicate the direction of the stack outlet: (check one)
Upward O Downward ❑Upward with obstructing raincap
❑Horizontal O Other(describe):
Indicate the stack opening and size: (check one)
❑Circular Interior stack diameter(inches): 48
❑Square/rectangle Interior stack width (inches): Interior stack depth(inches):
❑Other(describe):
co�oRsoo
Permit Number: 12WE1828 AIRS ID Number: 123 /9892/004
Section 6 - Control Device Information
0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
❑✓ Loading occurs using a vapor balance system: Requested Control Efficiency: 100 . %
Used for control of: VOC.HAPs
Rating: 0.03 MMBtu/hr
Combustion Type: Enclosed Combustor Make/Model: Three(3)LEED L3-0010 ECDs
Device: Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98 %
Minimum Temperature: N/A F Waste Gas Heat Content: 2.204 Btu/scf
Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: N/A MMBtu/hr
Pollutants Controlled:
0 Other: Description:
Requested Control Efficiency:
Section 7 Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? Yes 0 No
If yes, describe the control equipment AND state the collection and control efficiencies(report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Collection Efficiency Control Efficiency
Pollutant Control Equipment Description (%of total emissions captured (%reduction of captured
by control equipment) emissions)
PM
SO.
NO.
CO
VOC ECD 100 95
HAPs ECD 100 95
Other:
0 Using State Emission Factors(Required for GP07) VOC Benzene n-Hexane
0 Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL
0 Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL
From what year ;s the following reported actual annual emissions data? 2019
Use the following table to report the criteria pollutant emissions from source:
Emission Factor Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Pollutant Source Uncontrolled Controlled Uncontrolled Controlled
Uncontrolled Units (Ap 41, Emissions Emissions6 Emissions Emissions
Basis Mfg.,etc.)
(tons/year) (tons/year) (tons/year) (tons/year)
PM 40 N9/L AP-42 0.002 0.002 0 002 0.002
SOx 0.00026 lb/MMBtu AP-42 <0.001 <0.001 <0.001 <0.001
NOx 0.068 Ib/MMBtu AP-42 0.009 0.009 0.009 0009
CO 0.310 Ib/MMBtu AP-42 0.041 0.041 0.041 0.041
VOC 0.236 Iblbbl State Default 7 77 0 39 7.77 0.39
5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider
future process growth. Requested values are required on alt APENs,including APEN updates.
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide
projected emissions.
COLORADO
4H.aaiuDeW Pub'
. .. b-nv.mnmen,
Permit Number: 12WE1828 AIRS ID Number: 123 /9892/004
Section 8 - Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteria Yes ❑ No
pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year?
If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source:
Chemical Emission Factor Actual Annual Emissions
Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled
Service (CAS) Basis Units (AP-42, Emissions Emissions6
Number Mfg.,etc.) (lbs/year) (lbs/year)
Benzene 71432 0 0004 lb/bbl State Default De Minn* De Minims
Toluene 108883 N/A N/A N/A N/A N/A
Ethylbenzene 100414 N/A N/A N/A N/A N/A
Xylene 1330207 N/A N/A N/A N/A N/A
n-Hexane 110543 0.0036 lb/bbl State Default De Mmimis De Minims
2,2,4-Trimethylpentane 540841 NIA N/A N/A N/A N/A
Other:
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide
projected emissions.
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source
is and will be operated in full compliance with each condition of General Permit GP07.
/ r� f2 2... 6/8/2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
Alisson Soehner Environmental Engineer, Air Quality
Name(print) Title
Check the appropriate box to request a copy of the:
❑Draft permit prior to issuance
Q Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit For more information or assistance call:
registration fee of$312.50, if applicable, to:
Small Business Assistance Program
Colorado Department of Public Health and Environment (303)692-3175
Air Pollution Control Division OR
APCD-SS-B1 (303)692-3148
4300 Cherry Creek Drive South
Denver, CO 80246-1530 APCD Main Phone Number
(303)692-3150
Make check payable to:
Colorado Department of Public Health and Environment
^^�. COLORADO
- .." Gas Venting APEN - Form APCD-211
40 440
Air Pollutant Emission Notice (APEN) and
CDPHE Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment
for a new filing fee.
This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head
casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks,etc.). In addition, the General APEN (Form APCD-200)is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD)website.
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 12WE 1828 AIRS ID Number: 123 /9892 /016
Section 1 - Administrative Information
Company Namet: Bonanza Creek Energy Operating Company, LLC
Site Name: Pronghorn 11.14-5HZ Production Facility(C0GCC#427089)
Site Location
Site Location: NWNW Sec 5, T5N, R61W Weld
County:
40.43678, -104.24139
NAICS or SIC Code: 1311
Mailing Address: 410 17th Street, Suite 1400
(Include Zip Code)
Denver, CO 80202 Contact Person: Alisson Soehner
Phone Number: (303) 803-1752
E-Mail Address2: asoehner@bonanzacrk.com
1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD.Any changes will require additional paperwork.
2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
432355
ionigrik COLORADO
1 . ownm�maaK
x<rme m��me�,
Permit Number: I2WE 1 828 AIRS ID Number: 123 /9892/016
Section 2 - Requested Action
❑ NEW permit OR newly-reported emission source
-OR-
MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name3 0 Add point to existing permit
0 Change permit limit ❑ Transfer of ownership4 ❑ Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes: Requesting updated throughput and emission limits based on previously
established emission factors.
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106)must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted.
Section 3 - General Information
General description of equipment and purpose: Low pressure gas flaring controlled by
three (3) enclosed combustion devices.
Company equipment Identification No. (optional): LPGFL
For existing sources, operation began on: 03/1/2012
For new, modified, or reconstructed sources, the projected start-up date is:
r❑Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
Will this equipment be operated in any NAAQS
Q Yes 0 No
nonattainment area?
Is this equipment located at a stationary source that is ❑ Yes 0 No
considered a Major Source of(HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
✓❑ Yes 0 No
Section XVII.G?
e4GOIORADO
Department N Pudk
Permit Number: 1 2WE 1 828 AIRS ID Number: 1 23 /9892/016
Section 4 - Process Equipment Information
0 Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model: Serial#: Capacity: gal/min
❑ Compressor Rod Packing
Make: Model: #of Pistons: Leak Rate: Scf/hr/pist
❑ Blowdown Events
#of Events/year: Volume per event: MMscf/event
❑ Other
Description:
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? Ei Yes ❑ No
Vent Gas 2 470 BTU/SCF
Gas Venting Heating Value: �
Process Parameters5: q 11.00 y 11.00 MMSCF/year
Requested: MMSCF/year Actual: MMSCF/ ear
-OR-
Liquid Throughput
Process Parameters5: Requested: bbl/year Actual: bbl/year
Molecular Weight: 44.3
VOC(Weight%) 80.3539
Benzene(Weight%) 0.1908
Vented Gas Toluene(Weight%) 0.1033
Properties: Ethylbenzene(Weight%) 0.0110
Xylene(Weight%) 0.0332
n-Hexane(Weight%) 1.6359
2,2,4-Trimethylpentane(Weight%) 0.1204
Additional Required Documentation:
D Attach a representative gas analysis(including BTEX& n-Hexane, temperature, and pressure)
❑ Attach a representative pressurized extended liquids analysis(including BTEX Et n-Hexane, temperature, and
pressure)
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable,and should consider
future process growth. Requested values are required on all APENs,including APEN updates.
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Permit Number: 1 2WE 1 828 AIRS ID Number: 123 /9892/0 16
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.43678,-104.24139
❑Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Operator Discharge Height Temp. Flow Rate Velocity
Stack ID No. Above Ground Level (•F) (ACFM) (ft/sec)
(Feet)
ECD 01-03 25 500 N/A N/A
Indicate the direction of the stack outlet: (check one)
0 Upward O Downward O Upward with obstructing raincap
❑Horizontal ❑Other(describe):
Indicate the stack opening and size: (check one)
0 Circular Interior stack diameter (inches): 48
❑Square/rectangle Interior stack width (inches): Interior stack depth (inches):
❑Other(describe):
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
Size: Make/Model:
❑ VRU:
Requested Control Efficiency:
VRU Downtime or Bypassed: %
Pollutants Controlled: VOC, HAPs
Rating: 3.11 MMBtu/hr
Type: Enclosed Combustor Make/Model: Three (3) LEED L30-0010
0 Combustion Requested Control Efficiency: 95
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: 500 Waste Gas Heat Content: 2,470 Btu/scf
Constant Pilot Light: O Yes 0 No Pilot burner Rating: N/A MMBtu/hr
Pollutants Controlled:
O Other: Description:
Requested Control Efficiency: %
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Permit Number: 12WE 1828 AIRS ID Number: 123 /9892/016
Section 7 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑r Yes O No
If yes, describe the control equipment AND state the collection and control efficiencies(report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Collection Efficiency Control Efficiency
Pollutant Control Equipment Description (%of total emissions captured (%reduction of captured
by control equipment) emissions)
PM
SOx
NOx
CO
VOC ECD 100 95 '
HAPs ECD 100 95
Other:
From what year is the following reported actual annual emissions data? 2019 i
Use the following table to report the criteria pollutant emissions from source:
Emission Factor Actual Annual Emissions Requested Annual Permit
Emission Limit(s)5
Pollutant Source Uncontrolled Controlled Uncontrolled Controlled
Uncontrolled Units (AP-42, Emissions Emissions6 Emissions Emissions
Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year)
PM 40 0 ug/L AP-42 0 15 0.15 0.15 0.15
SOx <0.001 Ib/MMBtu AP-42 <0 001 <0.001 <0.001 <0.001
NOx 0 068 Ib/MMBtu AP-42 0 93 0.93 0.93 0.93
CO 0.310 Ib/MMBtu AP-42 4 23 4.23 4 23 4.23
VOC 93,815.89 tb/MMscf Permit 14 516.00 25 80 516 00 25.80
5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider
future process growth. Requested values are required on all APENs,including APEN updates.
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide
projected emissions.
Section 8 - Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteria Yes O No
pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year?
If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source:
Chemical Emission Factor Actual Annual Emissions
Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled
Service(CAS) Basis Units (AP-42, Emissions Emissions6
Number Mfg.,etc.) (lbs/year) (lbs/year)
Benzene 71432 222.77 Ibibbl Permit 14 2,452 124
Toluene 108883 120 61 Ib/bbl Permit 14 1.328 68
Ethylbenzene 100414 12 84 Ib/bbl Permit 14 De Minimis De Minimis
Xylene 1330207 38.76 lb/bbl Permitl4 428 22
n-Hexane 110543 1,909 99 Ib/bbl Permit 14 21.010 1,052
2,2,4-Trimethylpentane 540841 14057 Ib/bbl Permit 14 1,548 78
Other:
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
COLORADO
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Permit Number: 1 2WE 1828 AIRS ID Number: 123 /9892/016
Section 9 - Applicant Certification
I hereby certify that alt information contained herein and information submitted with this application is complete,
true, and correct.
avy3 - /"y' L 6/8/2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
Alisson Soehner Environmental Engineer, Air Quality
Name (print) Title
Check the appropriate box to request a copy of the:
Draft permit prior to issuance
❑� Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 to: For more information or assistance call:
Colorado Department of Public Health and Environment Small Business Assistance Program
Air Pollution Control Division (303)692-3175
APCD-SS-B1 OR
4300 Cherry Creek Drive South (303) 692-3148
Denver, CO 80246-1530
APCD Main Phone Number
Make check payable to: (303) 692-3150
Colorado Department of Public Health and Environment
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