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HomeMy WebLinkAbout20203457.tiff y C .,XY": COLORADO `_jll° Department of Public ��i1� Health&Environment Weld County - Clerk to the Board 1150 O St PO Box 758 RECEIVED Greeley, CO 80632 NOV 16 2020 November 2, 2020 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On November 3, 2020, the Air Pollution Control Division will begin a 30-day public notice period for Bonanza Creek Energy Operating Company, LLC - State Seventy Holes T-6 Production Facility. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health a Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator fir A1� 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.cotorado.gov/cdphe (F.7, i _"4 t"%, Jared Polis,Governor I Jilt Hunsaker Ryan,MPH, Executive Director it .,)#) cc,PLCTP), HLCOS), OC,CJfh), PUtoIiC view PW( ..R,CHIJM/cK) 2020-3457 IIfa318o It/ I-7 rao �yy�i/. Air Pollution Control Division o r4 CDPHE Notice of a Proposed Project or Activity Warranting Public C Comment Website Title: Bonanza Creek Energy Operating Company, LLC - State Seventy Holes T-6 Production Facility - Weld County Notice Period Begins: November 3, 2020 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Bonanza Creek Energy Operating Company, LLC Facility: State Seventy Holes T-6 Production Facility This facility is classified as a well production facility. SESE Section 6, T4N, R62W Weld County The proposed project or activity is as follows: This modification updates emission and throughput limits for the condensate storage tanks, condensate truck loadout and separator venting to be reflective of current facility operations. 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 14WE0328 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Elie Chavez Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO Department of Public 1 IMOP c"' Health&Environment �•— COLORADO IIP 4 Air Pollution Control Division iii Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 14WE0328 Issuance: 2 Date issued: Bonanza Creek Energy Operating Issued to: Company, LLC Facility Name: State Seventy Holes T-6 Production Facility Plant AIRS ID: 123-9BF4 Physical Location: SESE SEC 6 T4N R62W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID Condensate Nine (9) 500 ba tankrrel fixed roof atmospheric storage 004 Enclosed Flare(s) storage vessels used to store condensate TL 006 Truck loadout of condensate by submerged Enclosed Flare(s) fill using vapor balance One (1) pneumatic water transfer pump P-1 008 (Sandpiper, Model G1 F, Serial number Enclosed Flare(s) 2076862), rated at 600 scf/hr Sep 1, 2, 3 010 Three (3) high/low-pressure (HLP) Enclosed Flare(s) separators Point 008: 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 the specific general terms and conditions included in this document and the following specific terms and conditions. Page 1 of 15 C ��.,- COLORADO t�, Air Pollution Control Division urf Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 NO,t VOC CO Type Condensate 004 --- --- 10.0 --- Point storage tank TL 006 --- --- 0.65 --- Point P-1 008 --- --- 2.7 1.4 Point Sep-1, 2, 3 010 --- -- 18.9 3.9 Point 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.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID Page 2 of 15 .may COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Condensate 004 Enclosed Flare(s) VOC and HAP storage tank TL 006 Enclosed Flare(s) VOC and HAP P-1 008 Enclosed Flare(s) VOC and HAP Sep-1, 2, 3 010 Enclosed Flare(s) VOC and HAP PROCESS LIMITATIONS AND RECORDS 5. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID Condensate 004 Condensate Throughput 109,500 bbl storage tank TL 006 Condensate Loaded 109,500 bbl P-1 008 Natural Gas 5.3 MMscf Sep-1, 2, 3 010 Natural Gas Vented 12 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. 6. Point 010: The owner or operator shall continuously monitor and record the volumetric flowrate of natural gas vented from the low pressure side of the HLP separators to the enclosed flare(s) using a flow meter. The flow meter shall continuously measure flowrate and record total volumetric flow of the waste gas(es) routed to the enclosed flare(s). The flow meter must be calibrated and maintained per the manufacturer's specifications and schedule. The owner or operator shall use the monthly throughput records, as required by the 08M Plan for this point, 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 Page 3 of 15 CCOLORADO '•.(40N- Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 7. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 8. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 9. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Part D, Sections I.C.1.d or II.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. Et 4.) 10. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.5.) ) 11. Points 004, 006: The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, 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 property. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 12. Point 004: 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; • Ensure that all hydrocarbon liquids and produced water collection, storage, processing, and handling operations, regardless of size, must be designed, operated, and maintained so as to minimize emission of volatile organic compounds to the atmosphere to the maximum extent practicable. (Regulation Number 7, Part D, Section I.C.); and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Part D, Section I.C.) (State only enforceable) 13. Point 004: 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 Page 4 of 15 • 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 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. 14. Point 004: The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2. 15. Point 006: 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) 16. Point 006: 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 15 (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. 17. Point 006: 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. 18. Point 006: 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. • 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. 19. Point 006: Storage tanks must operate without venting at all times during loadout. (Regulation Number 7, Part D, Section II.C.5.a.(ii)) 20. Point 006: The owner or operator must, as applicable (Regulation Number 7, Part D, Section II.C.5.a.(iii)): Page 5 of 15 COLORADO C404';401°I Air Pollution Control Division Department of Public Health Ex Environment Dedicated to protecting and improving the health and environment of the people of Colorado • 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. 21. Point 006: 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. 22. Point 006: 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. Page 6 of 15 •r,:fx COLORADO IP � _ Air Pollution Control Division Department of Pubiic Health f&Environment Dedicated to protecting and improving the health and environment of the people of Colorado • Records of the annual training program, including the date and names of persons trained. 23. Point 006: 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)) 24. Point 008: 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. 25. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING Ft MAINTENANCE REQUIREMENTS 26. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 27. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements Page 7 of 15 xT.•� COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 28. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ALTERNATE OPERATING SCENARIOS 29. Point 008: 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. 30. Point 008: 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. 31. Point 008: 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 32. All previous versions of this permit are cancelled upon issuance of this permit. 33. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) 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 Page 8 of 15 ,•r,� ... COLORADO _„of Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado • No later than 30 days before the existing APEN expires. 34. 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 p Equipment Point Description Pollutant ID Threshold Permit Limit Condensate 004 Storage Tank storage tank Liquid TL 006 Loadout P-1 008 Pneumatic VOC 50 39.4 Pump Venting Separator Sep-1, 2, 3 010 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 35. 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. 36. 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 Page 9 of 15 :.:r. COLORADO 4 44.4‘00 Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 37. 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. 38. 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. 39. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 40. 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. 41. 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 10/14/2014 Issued to Bonanza Creek Energy Operating Company, LLC Issuance 2 This Issuance Point 004: Modified throughput and emission Page 10 of 15 COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado factors Point 005: Removed point from permit - below thresholds Point 006: Modified throughput and emission factors Point 007: Removed point from permit - below thresholds Point 009: Removed point from permit - equipment no longer exists Point 010: Modified throughput and emission factors Page 11 of 15 -r•a� COLORADO Air Pollution Control Division Department of Public Health&Envtronment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (Ib/yr) (lb/yr) Benzene 71432 5,323 266 Toluene 108883 4,240 212 Ethylbenzene 100414 361 18 001 Xylenes 1330207 1,388 69 n-Hexane 110543 29,898 1,495 2,2,4- 540841 Trimethylpentane 1,539 77 Benzene 71432 45 2 Toluene 108883 0 0 Ethylbenzene 100414 0 0 006 Xylenes 1330207 0 0 n-Hexane 110543 394 20 2,2,4- 540841 0 0 Trimethylpentane 008 Benzene 71432 245 12 Page 12 of 15 -- COLORADO o N_ r/ Air Pollution Control Division i Department of Public tfeatth&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Toluene 108883 170 9 Ethylbenzene 100414 16 1 Xylenes 1330207 53 3 n-Hexane 110543 1,543 77 2,2,4- 540841 --- --- Trimethylpentane Benzene 71432 2,648 132 Toluene 108883 1,992 100 Ethylbenzene 100414 178 9 010 Xylenes 1330207 719 36 n-Hexane 110543 16,773 839 2,2,4- 540841 10 1 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 004: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl VOC 3.6554 0.1828 71432 Benzene 0.0486 0.0024 108883 Toluene 0.0387 0.0019 100414 Ethylbenzene 0.0033 0.0002 Site Specific 1330207 Xylene 0.0127 0.0006 Sample + ProMax 110543 n-Hexane 0.2730 0.0137 540841 2'2'4 0.0141 0.0007 Trimethylpentane Note: The controlled emissions factors for this point are based on a control efficiency of 95%. The emission factors listed above are based on a ProMax simulation conducted on 4/24/2020 using a site-specific extended liquids analysis obtained on 12/12/2013 at 40 psig and 120'F. Point 006: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl VOC 0.236 0.01180 State Default Emission Factors 110543 n-Hexane 0.0036 0.00018 for Condensate Note: Controlled emission factors are based on a flare efficiency of 95%and a collection efficiency of 100%. Page 13 of 15 Ct4;r COLORADO AO Air Pollution Control Division ie department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Point 008: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/MMscf vented lb/MMscf vented CO AP-42 Chapter (lb/MMBtu) 0.31 0.31 13.5 V0C 20240.5057 1012.0253 Gas Analysis 71432 Benzene 46.5775 2.3289 Gas Analysis 108883 Toluene 32.3341 1.6167 Gas Analysis 1330207 Xylene 10.0848 0.5042 Gas Analysis 110543 n-Hexane 293.5577 14.6779 Gas Analysis Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Point 010: Weight Uncontrolled Controlled Fraction of Emission Emission CAS # Pollutant Gas (%) Factors Factors Source lb/MMscf lb/MMscf CO --- 644.18 644.18 AP-42 Chapter 13.5 V0C 65.37% 62,933.79 3,146.69 Gas Analysis 71432 Benzene 0.23% 220.67 11.03 Gas Analysis 108883 Toluene 0.17% 165.99 8.30 Gas Analysis 1330207 Xylene 0.06% 59.89 2.99 Gas Analysis 110543 n-Hexane 1.45% 1,397.79 69.89 Gas Analysis Note: The controlled emissions factors for this point are based on a control efficiency of 95%. The VOC and HAP emission factors listed above are based on a site-specific extended gas analysis obtained from the low pressure side of the HLP separators on 12/12/2013 at 43 psig and 120'F. The weight%values listed in the table above and molecular weight (36.5 lb/lbmol)were used with the displacement equation (EPA Emission Inventory Improvement Publication, Volume II, Chapter 10)to determine the emission factors. The CO emission factor was obtained by converting the AP- 42, Chapter 13.5 factor from lb/MMBtu to lb/MMscf using a waste gas heat content of 2,078 Btu/scf. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Page 14 of 15 ,,-7 COLORADO Air Pollution Control Division Department of Public Health C Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart 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 15 of 15 Cobrado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Elie Chavez Package 8: 431118 Received Date: 5/8/2020 Review Start Date: 10/9/2020 Section 01-Facility Information Company Name: Bonanza Creek Energy Operating Company,LLC Quadrant Section Township Range County AIRS ID: 123 SESE 6 4N 62 Plant AIRS ID: 98F4 Facility Name: State Seventy Holes T-6 Production Facility ...r�� ,,0 ., Physical Address/Location: , , :uisge 62W County: Weld County Type of Facility: Exploration&Production Well Pad What industry segment?Oil&Natural Gas Production&Processing Is this facility located in a NAAQS non-attainment area? Yes If yes,for what pollutant? Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only Permit 3 AIRs Point# 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( Condensate Storage Permit 004 Storage Tank Tank Yes 14WE0328 2 No Modification Permit 006 Liquid Loading TL Yes 14WE0328 2 No Modification Permit 010 Separator Venting SEP-1,2,3 Yes 14WE0328 2 No Modification Section 03-Description of Project This modification permits new emission factors and throughput limitations the condensate storage tanks(AIRS 004),condensate truck Ioadout(AIRS 006)and high/low pressure(HLP)separators(AIRS 010).In addition,the following changes were made to the construction permit: 1.Facility-wide HAP limits were included with this issuance of 14WE0328 as uncontrolled potential HAP emissions from this facility exceed the major source threshold of 10 tons/year individual HAP(n-Hexane)and 25 tons/year total HAP.Because control devices are used to achieve controlled HAP emissions below the major source thresholds,synthetic minor HAP limitations of 8 tons/year individual HAP and 20 tons/year total HAP were included in this issuance of 14WE0328. 2.Removed all permit limitations and conditionsrelated to fugitive equipment leaks FUG(AIRS 007)as this point dropped below APEN and permitting thresholds in accordance with Colorado Regulation No.3,Part A,Section II.D.1.a.and Part B,Section II.D.1.a.,pursuant to a cancellation request received 8/27/2015. 3.Removed all permit limitations and conditions related to produced water storage tanks PW Tanks(AIRS 005)as this point dropped below APEN and permitting thresholds in accordance with Colorado Regulation No.3,Part A,Section II.D.1.a.and Part B,Section II.D.1.a.,pursuant to a cancellation request received 11/9/2018. 4.Removed all permit limitations and conditions related to the emergency flare FL-1(AIRS 009)as this point no longer exists on site,pursuant to a cancellation request received 11/9/2018. 5.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 10/14/2014.Although this modification request did not alter any permitted limitations for pneumatic pump P-1(AIRS 008), this pump is subject to the requirements of Section I.K.,as noted in the permit application received 5/8/2020.As such,these applicable requirements were incorporated into this issuance of the construction permit. 6.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 10/14/2014.This facility is subject to the requirements of Section V.,as noted in the permit application received 5/8/2020.As such,these applicable requirements were incorporated into this issuance of 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 Colorado Air Permitting Project Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? 7ro- If yes,for what pollutants? av If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? Mo A ,nI Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: S02 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) DODD ❑ ❑ Title V Operating Permits(OP) ❑ DOR ❑ ❑ ❑ 0 Non-Attainment New Source Review(NANSR) U U. Is this stationary source a major source? If yes,indicate programs and which pollutants: S02 NOa CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) U U IJ U U U Title V Operating Permits(OP) U U U U U ULU Non-Attainment New Source Review(NANSR) ❑ Section 01-Administrative Information (Facility AIRS ID: County Plant Point Section 02-Equipment Description Details Storage Tank Liquid jy ,- pdens2t₹ ; Detailed Emissions Unit Nine(9)500 barrel fixed roof atmospheric storage vessels used to store condensate Description: - Emission Control Device Six(6)LEED L30-0010 Enclosed Flares Description: Requested Overall VOC&HAP Control Efficiency at 95.0 Limited Process Parameter 4411,,i' a' } Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actual Throughput= 109,500.0 Barrels(bbl)per year (Requested Permit Limit Throughput= 109,500.0 Barrels(bbl)per year Requested Monthly Throughput= S,:''2. Barrels(bbl)per month Potential to Emit(PTE)Condensate Throughput= 109,500.0 Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= 2968.0 Btu/scf Volume of waste gas emitted per BBL of liquids produced= 29;8 scf/bbl 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: 100.8 scfh .-'MMscf/yr Pilot Fuel Gas Heating Value: 2968.02 Btu/scf . .MMBTU/yr • MW (. 53,5 Ib/Ib-mol Mass Flow From ProMax Argon/Oxygen 0,0 lb/hr CO2 0.4 lb/hr N2 - 0.2 lb/hr methane 0.9 lb/hr ethane 5.4 lb/hr propane 12.0 lb/hr isobutane 2.3 lb/hr n-butane 7.7 lb/hr isopentane 1:9 lb/hr n-pentane 2.4 lb/hr cyclopentane 1.1 lb/hr n-Hexane 3.4 lb/hr cyclohexane 1.0 lb/hr Other hexanes 6.7 lb/hr heptanes 2.7 lb/hr methylcyclohexane 0.0 lb/hr 224-TMP _ 0.2 lb/hr Benzene 0.6 lb/hr Toluene - 0,5 lb/hr Ethylhenzene 0.0 lb/hr Xylenes 0.2 lb/hr CB+Heavies : 1.3 lb/hr Total VOC - Section 04-Emissions Factors&Methodologies , Will this storage tank emit flash emissions? Emission Factors Condensate Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Condensate (Condensate Throughput) Throughput) VOC 3:6554: i i Site Specific E.F,(includes flash) E.., Benzene " 0,0486 0."=)24 Site:Specific E,F,(includes flash) Toluene 0.0387 :'f iRe Specific E.F,(includes flash) Ethylbenzene 0.0033 'Specific&F.(includes Flash) -. Xylene 0.0127 .,,,CC, E.F.(includes flash) n-Hexane 0,2730 a7 Specific OF.(includes flash) 224TMP 0.0L41r .-liar 0pedfic E.Ft,includes flash)2.; -2 Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source 3 of 14 K:\PA\2014\14W E0328,CP2 - -,'e Tank(s)Emissions Inventory (waste heat (Condensate combusted) Throughput) PM10 :0:0015 AP42Tabtmt4-2(PM10/PM.25) PM2.5 0.0075 AP42Ta)rle„i4-S(PM10/PM.25) 50x 0.0006 AP-42 1'461 442(5042-2:4O'7,, a. es NOn 0.0680 _ AP-42 Chanptet 13.5 lndustraaolFlares(NOx) - CO :0:3100 AP-42 t3tapt6e 13.5 lndan6rid}Flares(CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (Ib/MMscf) Emission Factor Source (Pilot Gas Heat (Pilot Gas Combusted) Throughput) PM10 ::0.0075 AP-42Tabfe324-2(PM10/PM.ZS) PM2.5 0.0075 AP-42 Talil 4.2)PM10/PM 25) 50x 0.0006 AP-42Tab(',4-2(50x) -:,y NOx 0.0680 AP-42 Cli e"t23.5 lndustriol'Flares(N0u} VOC 0:0054 - AP-42 Taile'1.4-2(VOC) CO 0.3100 AP-42 Chalker 13.5 Industrial Flares(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 PM2.5 ... .: SOx .. _ _. NOx _ ..- - -. VOC ,. .. ... CO .. . Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) IIbs/year) (Ihs/year) (Ihs/year) (lbs/year) Benzene -- __. Toluene _ _ , Ethylbenzene .. _ .. Xylene .. .._ __ = - n-Hexane - 224 TMP . 4 of 14 K:\PA\2014\14WE0328.CP2 e Tanks;Emissions inventory Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Regulation 7,Part D,Section I.C,0,E,F Regulation 7,Part D,Section I.G,C Regulation 7,Part D,Section I6B,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 II.C.4.a.(ii( Regulation 6,Part A,NSPS Subpart Kb Regulation 1,Part A,NSPS Subpart 0000 NSPS Subpart 0000a Regulation 8,Part E,MACE 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 t estimate emissions? te, If yes,are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than or equal to 80 tpy? If yes,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company use a site specific emissions factor to estimate emissions? o:#` If yes and if there re flash emissions,are the emissions factors based on a pressurized liquid sample drawn atthe facility being permitted(for produced water tanks,a pressurize liquid sample must be analyzed using flash liberation analysis)?This sample • should he considered representative which generally means site-specific and collected within one year tithe application r I.;" received date.However,if the facility has not been modified(e.g.,no new wells brought on-line),then it maybe appropriate to : u jj use an alder site-specific sample. If no,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Maine 14-03. • Does the company requesta control device efficiency greater than 95%for a flare or combustion device? k, . If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20.02 • Section 08-Technical Analysis Notes 1.Emission calculations based on a site specific sample obtained on 12/12/2013 at 40 psig and 120°F.As indicated in the permit application received 5/8/2020,no changes to these wells(i.e.,additional wells added,hydraulic refracturing,etc.)have occurred since the wells were originally commissioned.As such,this site-specific sample is considered to be"representative"for the purposes of this application and an initial requirement to obtain a new sample was not included in the construction permit. 2.The gas to oil ratio(GOR)was updated from the GOR listed in the 5/8/2020 application based on operator correspondence received 10/19/2020.The GOR presented in the 5/8/2020 application of 22.21 scf/bbl was based on the flowrate of VOCs only from the"Total Condensate Tank Emissions"stream calculated by ProMax.It was determined that the GOR should Re based on the total flow of emissions,not just the VOC emissions,as non-VOC components(i.e.,methane and ethane)contribute to both the total volume of emissions as well as the NO0 and CO generation from combustion of the emissions stream. Therefore,the GOR was calculated by dividing the total standard volumetric flowrate of the"Total Condensate Tank Emissions"stream in ProMax by the condensate throughput limitation to obtain an updated GOR(0.00894107 MMscf/day x 1,000,000 scf/MMscf/300 bbl/day=29.8 scf/bbl).As a result,this GOR was used in the Division's preliminary analysis and a redlined APEN with modified NOx and CO emissions was routed to the operator for approval, 3.NOx and CO emissions from this source are below APEN reporting thresholds.As a result,limits and emission factors are not included in the permit for NOx or CO. 4.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(0.007 tpy).This minimal amount of emissions does not impact the total VOC limit for this source and therefore can be ignored. 5.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. 6.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 APEN received with the 5/8/2020 application,the date of last storage vessel installation was 7/2013.As such, these condensate storage tanks are not subject to the provisions of Section II.C.4. 7.This facility is not subject to the storage vessel provisions of NSPS Kb as the vessels meet the exemption set forth in§60.110b(d)(4)which excludes storage vessels with a capacity less than or equal to 1,589.874 m3(^10,000 bbl)storing condensate prior to custody transfer.Each condensate storage vessel at this facility has a capacity of 500 bbl.Custody transfer is defined in§60.111b as"the transfer of produced petroleum and/or condensate,after processing and/or treatment in the producing operations,from storage vessels or automatic transfer facilities to pipelines or any other forms of transportation."By definition,a transfer of condensate from one facility to another must occur.Because the condensate stored at this facility is first treated at this facility and no transfer of facilities has occurred,the storage vessels are located prior to custody transfer.As such,these storage vessels fulfill both the capacity and custody transfer criteria of this exemption and are therefore not subject to NSPS Kb. 6.This facility is not subject to the storagevessel provisions of NSPS 0000/a as potential VOC emissions,when considering enforceable controls in accordance with 460.5365(e)and§60.5365a(e),are less than 6 tons/year. 9.This facility is not subject to the storage vessel provisions of MACT HIS as individual and total HAP emissions from this facility are below the 10 ton/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 411. Section 09-SCC Coding and Emissions Factors(For Inventory Use Only) 1. Uncontrolled Emissions AIRS Point# Process# SCC Cade Pollutant Factor Control%Units 444 01 " ^'' ,. v s' PM10 0.02 9 lb/1,000 gallons Condensate throughput PM2.5 0.02 9 lb/1,000 gallons Condensate throughput SOx 0.00 0 lb/1,000 gallons Condensate throughput NOx 0.10 0 lb/1,000 gallons Condensate throughput VOC 87.04 95 lb/1,000 gallons Condensate throughput CO 0.83 0 Ib/1,000 gallons Condensate throughput Benzene 1.16 94 lb/1,000 gallons Condensate throughput Toluene 0.92 95 lb/1,000 gallons Condensate throughput Ethylbenzene 0.08 95 lb/1,000 gallons Condensate throughput Xylene 0.30 OS lb/1,000 gallons Condensate throughput n-Hexane 6.50 95 lb/1,000 gallons Condensate throughput 224 TMP 0.33 95 lb/1,000 gallons Condensate throughput 5 of 14 K:\PA\2014\14W E0328.CP2 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 b in the NomAttainment Aces 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 and1.14 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))? 'Storage tank is subject to Regulation 7,Part 0,Section I.C-F - Part D,Section I.C.1—General Requirements for Air Pollution Control Equipment—Prevention of Leakage Part D,Section I.C.2—Emission Estimation Procedures Part D,Section I.D—Emissions Control Requirements q Part D,Section I.E—Monitoring Part D,Section I.F—Recordkeeping and Reporting Storage leek is not subject to Regulation 7,Section I:S Part 0,Section I.G.2-Emissions Control Requirements Part D,Section I.C.1.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 facility',natural gas compressor station'or natural gas processing pli 3. Does this storage tank have a fixed roof(Regulation 7,Part D,Section II.A.20)? 4. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year VOC(Regulation 7,Part D,Section II.C.1.c)? 'Storage Rbek is su :a Regulation 7,Part D Section II,R. 5.1&C 3 Part D,Section II.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Part D,Section II.C.1-Emissions Control and Monitoring Provisions Part D,Section II.C.3-Recordkeeping Requirements - 5. Does the storage tank contain only"stabilized"liquids(Regulation 7,Part D,Section II.C.2.b)? Storage tank is subject to Regulation 7,Part 0,Section 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 or after May 1,2020,such that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydra Storage Tank is not subject r Part D,Sectio^ii.C.4.as Is the controlled storage tank located at a well production facility,natural gas compressor station,or natural gas processing plant constructed on or after January 1,2021 i 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 not subject to Regulation 7,Part 0,Section 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 3)["'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 ti 3. Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)after July 23,1984(40 CFR 60.110b(a))? 4. Does the tank meet the definition of"storage vessel"'in 60.111b? 5. Does the storage vessel store a"volatile organic liquid(VOL)"s 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 m'[ 950 BBL]and stores a liquid with a maximum true vapor pressure a 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 a 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 m'[^'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 M5['472 BBL]but less than 151 m5[-950 BBL]and stores a liquid with a maximum true vapor pressure great Storage Tan: `c•NSPS Kb 40 CFR,Part 60,Subpart OOOO/OOOOa,Standards of Performance for Crude Oil and Natural Gas Production,Transmission and Distribution Is this storage vessel located at a facility in the onshore oil and natural gas production segment,natural gas processing segment or natural gas transmission and storage 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"2 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 NSPS OOOO [Note: If a storage-vessel is previously determined to be subject to NSPS OOOO/OOOOa due to emissions above 6 tons per year VOC on the applicability determinatior 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. It 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 major3 for HAPs? 3. Does the tank meet the definition of"storage vessel"4 in 63.761? 4. Does the tank meet the definition of"storage vessel with the potential for flash emissions"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 HH Subpart A,General provisions per§63.764(a)Table 2 §63.766-Emissions Control Standards §63.773-Monitoring §63.774-Recordkeeping §63.775-Reporting RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non-attainment area. If the tank meets both criteria,then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air 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, 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"recoil', "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 documr _lout Emissions inventory Section 01-Administrative Information 123 96F4 006 Facility AIRs ID: 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 Six(6)LEED L30-0010 Enclosed Flares Description: Is this loadout controlled? Yes Requested Overall VOC&HAP Control Efficiency%: 95 Section 03-Processing Rate Information far Emissions Estimates Primary Emissions-Hydrocarbon Loadout Actual Volume Loaded= 109,500 Barrels(hbl)per year 'Requested Permit Limit Throughput= 109,500.Barrels(bbl)per year Requested Monthly Throughput= 3300 Barrels(bbl)per month Potential to Emit)PTE)Volume Loaded= -109,500 Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= 2424;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= :11 MMBTU per year Requested heat content of waste gas routed to combustion device= 425 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 415 MMBTU per year Control Device Pilot Fuel Use Rate: - y �+ * scfh 0.0 MMscf/yr Pilot combustion accounted far at condensate storage tanks(Point 004) Pilot Fuel Gas Heating Value: (Btu/scf 0.i3 MMBTU/yr Section 04-Emissions Factors&Methodologies Does the company use the state default emissions factors to estimate emissions? Does the hydrocarbon liquid loading operation utilize submerged fill? The._en default e.- ,>>,.,c, to .,_.-ca to estimate eon,.s Emission Factors Hydrocarbon Loadout Uncontrolled Controlled Emission F actor Source Pollutant (lb/bbl) (lb/bbl) (Volume Loaded) (Volume Loaded) VOC _.3`0E-01 _._u=__ Condensate Loadout State.C.F. Benzene _35'e4 _ Condensate Loadout State E.F. Toluene .,,3=.,[-O0 i3E-O0 Condensate Loadout State E.F. Ethylbenzene •v:;C I I ?.0E<-UJ Condensate:Loadout State E.F. Xylene _E+Oil -205-d3 Condensate Loadout Sate E.F. n-Hezane .�__33 1..0E-04 Condensate Loadout State E.F. 224TMP -F^o0 Condensate Loadout State E.F. Control Device Uncontrolled Uncontrolled Pollutant Emission Factor Source (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Volume Loaded) PM10 0.0075 _, AP-42 Table 5.4-2(PMSO/PM.2.5) PM2.5 0.0075 .-, AP 42 Table SA-2(PN110/PM.2.5) SOx 0.0006 :- AP-42 Tahie 1.4-2)50x1 NOx 0.0680 AP-42 Chapter 13.5 Industrial Flares(NO3) CO 0.3100 _. AP-42 Chapter 13.5Indushial Flares(CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant )lb/MMBtu) )Ib/MMscf) Emission Factor Source (Pilot Gas (Waste Heat Combusted) Throughput) PM10 PM2.5 SOx Yi NOx kze vac yr co 3 of 14 K:\PA\2014\14WE0328.CP2 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 50x NOx VOC _:! -1= ;S ?'_ - CO Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (Ibs/year) (Ibs/year) (Ibs/year) (Ibs/yearl 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.S. _. -quids Ica, _..,u,-_is subject to i end I. ,. _.. (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 10/19/2020.Note that this heat content is more conservative than the state-default value of 2,255 Btu/scf for condensate storage tanks(PS Memo 14-03).As such,this heat content was considered to be acceptable for the purposes of this application. 2.Note that pilot gas emissions from the 6.combustors are calculated with the condensate tank point(AIRS 004). 3.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. 4.n-Hexane is the only reportable HAPs for this unit.As a result,this is the only HAP for which emission factors are 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 D,Section II.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. 7.Included requirement to operate and maintain the control device in order to reduce emissions to less than or equal to the limits established in the construction permit(Condition 4).Because the truck loading point utilizes a control device,it was added to the control device table of this.Condition 4. Section 09-SCC Coding and Emissions Factors(For Inventory Use Only) Uncontrolled Emissions AIRS Point# Process# SCC Code Pollutant Factor Control% Units 006 01 _ 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 4,2 35 lb/1,000 gallons transferred CO 03 0 lb/1,000 gallons transferred Benzene __ 35 lb/1,000 gallons transferred Toluene .3 lb/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\2014\14WE0328.CP2 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. Sources 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 ll.D.1.a)? 2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part B,Section II.D.1.1)? 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 5 TPY,NOx greater than 10 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section ll.D.3)? IYou hay,indicated -t sauced is in the Nan•Attainrrent Area NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY(Regulation 3,Part A,Section II.D.1.a)? 2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part B,Section II.D.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 from the greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section ll.D.2)? Ier;rit Colorado Regulation 7 Part D Section II.C.5. 1. Is this condensate storage tank hydrocarbon liquids loadout located eta 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? IThe hydrocarbon liquids loadout source is sub)ert to Regulation Pert C Satceo.r .3 Section II.C.5.a.(i)-Compliance Schedule Section II.C.5.a.(ii)-Operation without Venting Section II.C.S.a.(iii)-Loadout Equipment Operation and Maintenance Section II.C.5.a.(iv)-Loadout observations and Operator Training Section II.C.5.a.(v)-Records Section II.C.5.a.(vi)-Requirements for Air Pollution Control Equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This note rule or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances.This document does not change or substitute for regulation,or any other legally binding requirement and is not legally enforceable.In the event of any conflict between the language of this document and the language of the Clean Air Act,,, 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"requited"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 y Section 01-Administrative Information Facility AIRS ID: 123 9BF4 010 County Plant Point Section 02-Equipment Description Details Three(3)high/low pressure(HLP)separators Detailed Emissions Unit Description Six(6)LEED L30-0010 Enclosed Flares Emission Control Device Description: Requested Overall VOC&HAP Control Efficiency% 95 Limited Process Parameter Natural Gas Vented a'"',. ' "'*zm, t Gas meter ,yes,meter is currently installed and operational Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator Actual Throughput= 12.0 MMscf per year Requested Permit Limit Throughput= 12.0 MMscf per year Requested Monthly Throughput= MMscf per month Potential to Emit(PTE)Throughput= 12.,0 MMscf per year Secondary Emissions-Combustion Device(s)for Air Pollution Control Separator Gas Heating Value: 2078.0 Btu/scf Volume of waste gas emitted per BBL of liquids throughput: scf/bbl Control Device f Pilot combustion accounted for at condensate storage tanks(Point 004) Pilot Fuel Use Rate: scfh 0.1 MMsd/yr Pilot Fuel Gas Heating Value: Btu/scf Section 04-Emissions Factors&Methodologies Description Three(3)wells at this facility produce to three(3)heater treaters,which separate high pressure gas from liquids.The high pressure liquids are routed to three(3)high/low pressure(HLP)separators.The high pressure gas from the high pressure side of the HLP separators and the high pressure gas from the heater treaters are routed to the sales line.If this sales line becomes unavailable,the facility shuts in.The low pressure gas from the low pressure side of the HIP separators is typically routed to a vapor recovery unit(VRU)for compression,and then routed to the sales line.During vapor recovery unit downtime,the low pressure gas vented from the low pressure side of the HLP separators is routed enclosed flare(s)for control.In order to develop site specific emission factors,the operator obtained a gas sample from the low pressure side of the HLP separators on. 12/12/2013,The molecular weight and weight%values from the sample were used in conjunction with the Displacement Equation listed below to develop the site specific emission factors. MW I 36.5 Ib/Ib-mol Displacement Equation Ex=Q*MW*Xx/C Weight% Helium '.0.0 CO2 2.5 N2 0.1 methane 14.2 ethane -17.9 propane 28.5 isobutane 4.7 n-butane 15.3 isopentane 3.9 n-pentane 5.1 cyclopentane 0.4 n-Hexane 1.5 cyclohexane 0.4 Other hexanes 2.4 heptanes 1.5 methylcyclohexane - 0.3 224-TMP 0.0 Benzene 0.2 Toluene '0.2 Ethylbenzene :°0.0 Xylenes 0.1 C8+Heavies 1.0 Total VOC Wt% • 11 of 14 K:\PA\2014\14WE0328.CP2 Separator Venting Emissions -s_r tor, Emission Factors Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (lb/MMscf) (Ib/MMscf) (Gas Throughput) (Gas Throughput) VOC 99953-739- _ .6536 Extended gas analysis Benzene 71756.6'3=_s 1.033-7 Extended gas analysis Toluene 105.5862 8.2553 Extended gas analysis Ethylbenzene 14597_71 0.7414: Extended gas analysis Xylene 59.88110 29943 ,x5,Extended gas analysis n-Hexane J757 7SO4 69.8958 r Extended gas analysis 224 TMP e 1665 0 53 Extended gas analysis Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 _ 15,48331 > AP-42 Table 1.4-2(PMiO/PM.2.5) PM2.5 0.0075 AP-42 Table 1.4-2(PM10/PM.2.5) SOx 0.0006 AP-42 Table 1.4-2(50x) NOx 0.0680 _ .-42 Chapter 13.5 Industrial Flares(Non) CO 0.3100 _ -42 Chapter 13.5 Industrial Flares(CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM10 0.0009 PM2.5 n r-,,,-- -e. SOx NOx 95 116671461V36714,595 .0.56:959.,6I5511t16-7:431991-I-65-56691 VOC . 65 6-3766,5160197-795,7513536534665657-66'5,667:96,6-535653.65 s 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 a 0 i G.! Cl. ,,,, PM2.5 0.= 0.1 0.1 0.7. .. 16 SOx 3.,, 0.0 0.0 0.:, __ 1 NOx .... 0,8 0.8 0.3 0.' 144 VOC - 3 3 377.1 1550 3676 __._ 3137 CO :. 3.9 3..9 3.9 _ 757 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (1hs/year) (Ibs/year) (Ibs/year) (Ibs/year) Benzene 26,1e _s4? 132 2649 132 Toluene !902 100 1932 103 Ethylbenzene .. .. 178 9 1'18 Xylene 713 36 719 36 n-Hexane 10773 039 16773 939 224 TMP _.. 10 _ 13 1 Section 06-Regulatory Summary Analysis Regulation 3,Parts A,8 50 requires 3 pc-n`it , Regulation 7,Part D,Section II.B,F -'1 not sub;e_ _.. 4 _.: ,__- Regulation 7,Part D,Section 11.8.2.e :The cot-7,701 device r-this sec„ra,. s not sv't 3egul.. :.-Part D E--'=cn.1 S.2.e (See regulatory applicability worksheet for detailed analysis) 12 of 14 K:\PA\2014\14WE0328.CP2 Separator Venting Emissions inventory Section 07-Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance zm Does the company use site specific emission factors based on a gal 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? 3m If yes,the permit will contain: -An"Initial Testing Requirement"to collect a site-specific as 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? 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 EirF'y1 y w.e✓Url r �,�U//ia_("./rte/ / //, .i14° x. . t° / ,yPt s s ri't� €)j. ,, s/ /, 4 °s 4,'",06:ATMATe/X5cMilf-00410104414-40.4.4#140110,0W*Atiffi4e,K$V010,70025 4v- a,. - �� }/x,. / ��' %fl,'/Ed.sp/'3 .,a , .n ',,5'/'? i=%1 000c%i.i,₹=:t a mx 4t ° ,s i'z i sf° , Section 08-Technical Analysis Notes 1.Emission calculations are based on a site-specific sample obtained on 12/12/2013 at 43 psig and 120°F.As indicated in the permit application received 5/8/2026,no changes to these wells(i.e.,additional wells added,hydraulic refracturing,etc.)have occurred since the wells were originally commissioned.As such,this site-specific sample is considered to be"representative"for the purposes of this application and an initial requirementto obtain a new sample was. not included in the construction permit. 2.Total permitted emissions from this facility are<40 tons/yearVOC.As such,initial and periodic extended gas analyses are not required. 3.Note that pilot gas emissions from the 6 combustors are calculated with the condensate tank point(AIRS 004). 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. S.Benzene,toluene,xylene and n Hexane 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 requirementto install a flowmeter(Previous Condition 6 of 14WE0328).This flowmeter was installed in accordance with the self-certification requirements 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. 7.Included requirementto 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 not subject to the Colorado Regulation No.7,Part D,Section lI.F.control of emissions from well production facilities requirements.All wells located at this facility were constructed and stimulated prior to 8/1/2014 and have not been restimulated since.As such,these separators are not subject to the separator control requirements of Section II.P.It should be noted,however,that these separators are controlled by six enclosed flares to meet the emission limitations required by 14WE0328. Section 09-SCC Coding and Emissions Factors(For Inventory Use Only) AIRS Point# Process# SCC Code Pollutant Uncontrolled Emissions Factor Control% Units 010 01 ":'0-G .v.- PM10 _. _ PM2.5 I C._ 500 C NOx c VOC CO c+ 0 lb/M vii:"- Benzene ems_. :5 Pb/Mss sue; Toluene 95 Ib/'.' Ethylbenzene .4 3 9.9 I °'S?₹r c Xylene 59,9 95 In/M,,,-, n-Hexane 139'.E 224TMP _-9 95 _.,= 13 of 14 K:\PA\2014\14WE0328.CP2 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 'Source t e Non-Attainment Are 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 'Source requires a permit Colorado Regulation 7,Part D,Section II 1. Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014? - 'cc is not subject to Regulation 7,Part D,Section l3.B.2;F Section ll.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 'The control devi. yt subject to Regulation 7,Part D,Section 11.5.e 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 lanc statute or regulation will control. The use of non-mandatory language such as"recommend,""may,""should,"and"can,"is ini 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 e Tan (s) APEN Form APCD-205 cPFHE Air Pollutant Emission Notice (APEN) and. Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source(e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 14WE0328 AIRS ID Number: 123 / 9BF4 /004 Section 1 - Administrative Information Company Name': Bonanza Creek Energy Operating Company,LLC(BCEOC) Site Name: State Seventy Holes 7-6 Production Facility(COGCC#433001) Site Location Site Location: SESE, 4N, 6, 62W County: Weld 40.33549, -104.363 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. 431113 • COLORADO RWU B Grtrvmmm Permit Number: 14WE0328 AIRS ID Number: 123 /9BF4/004 Section 2 - Requested Action O NEW permit OR newly-reported emission source ❑ Request coverage under traditional construction permit ❑ Request coverage under a General Permit O GP01 ❑ 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- ✓❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name3 D Change permit limit 0 Transfer of ownership4 O Other(describe below) -OR • APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- CD APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Requesting new throughput and emission limits based on updated 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): Condensate storage tank For existing sources, operation began on: 11/11/2013 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: ✓❑ Exploration Et Production (EEtP)site O Midstream or Downstream (non E&P)site Will this equipment be operated in any NAAQS nonattainment area? ❑ Yes O No Are Flash Emissions anticipated from these storage tanks? ❑✓, Yes ❑ No Is the actual annual average hydrocarbon liquid throughput≥ 500 bbl/day? O Yes ❑✓ 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) ❑ Yes 0 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 ❑✓ No emissions a 6 ton/yr(per storage tank)? 0O64%.x. Permit Number: 14WEO328 AIRS ID Number: 123 /9BF4/004 Section 4 - Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbl/year) (bbl/year) Condensate Throughput: 109,500 109,500 From what year is the actual annual amount? 2019 Average API gravity of sales oil: 39.5 degrees RVP of sales oil: 7 Tank design: Q Fixed roof O Internal floating roof O 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) CNDTK01-09 Nine(9)500 bbl 4,500 7/2013 11/2013 Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 37914 State Seventy Holes 34-31-6HNB O 05 - 123 - 37928 State Seventy Holes O-K-6HNB O 05 - 123 • 37405 State Seventy Holes T-P-6HNB O O O 5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 6 The E$P Storage Tank APEN Addendum (Form APCD-212)should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.33549,-104.363 O 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 01-06 —25 500 TBD TBD Indicate the direction of the stack outlet: (check one) 0 Upward ❑Downward O Upward with obstructing raincap ❑Horizontal ❑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): COLORxw er,,,a, �..n Permit Number: 14WE0328 AIRS ID Number: 123 /9BF4/004 Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: ❑ Recovery Unit(VRU): Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): Pollutants Controlled: VOC, HAPs Rating: 1.12 MMBtu/hr Type: Enclosed Combustor Make/Model: Six(6) LEED L30-0010 ❑ Combustion Requested Control Efficiency: 95 % Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: 500 Waste Gas Heat Content: 2,968 Btu/scf Constant Pilot Light: 0 Yes ❑ No Pilot Burner Rating: 0.30 MMBtu/hr Description of the closed loop system: ❑ Closed Loop System Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (EEtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 40 psig Describe the separation process between the welt and the storage tanks: Well produces to a separator where condensate is separated out and routed to the condensate tank battery. COLORADO - Na�sltn6Cnrrtm�inen Permit Number: 14WE0328 AIRS ID Number: 123 /9BF4/004 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? ❑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 (X reduction of captured by control equipment) emissions) V0C 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 AP-4Y Basis Units ( Emissions Emissions8 Emissions Emissions Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tans/year) VOC 3.6550 lb/bbl ProMax 200.11 10.01 200.11 10.01 NOx 0.068 Ib/MM8tu AP-42 0 34 0.34 a34 0.4 034 0.4 CO 0.370 Ib/MMBtu AP-42 153 7.53 1-33 1.9 1-53 1.9 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. EJC per 7 Attach condensate liquid laboratory analysis,stack test results,and associated emissions calculations if you are requesting site email rec'd specific emissions factors according to the guidance in PS Memo 14-03. 1 0/28/2020 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-criteria0 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 Emissions8 Number Mfg.,etc.) Ohs/year) (lbs/year) Benzene 71432 00486 lb/bbl ProMax 5,323 268 Toluene 108883 0,0387 lb/bbl ProMax 4,240 212 Ethylbenzene 100414 0.0033 lb/bbl ProMax 361 20 Xylene 1330207 00127 lb/bbl ProMax 1 388 70 n-Hexane 110543 02730 b,bbl ProMax 29.894 1,496 2,2,4-Trimethylpentane 540841 0.0141 lb/bbl ProMax 1.538 78 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 ....-.,==-- Permit Number: 14WE0328 AIRS ID Number: 123 /9BF4/004 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. a .- �y � 5/04/2020 Signature of Legally Authorized Person (not a vendor or consultant) Date Alisson Soehner Environmental Engineer,Air Quality Name(print) Title Check the appropriate box to request a copy of the: Q Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $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 ice.....COLORADO i a Harr Hydrocarbon Liquid Loading APEN 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 locks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source(e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN(Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website. This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 14WE0328 AIRS ID Number: 123 / 9BF4 /006 Section 1 -Administrative Information Company Name': Bonanza Creek Energy Operating Company.LLC(BCEOC) Site Name: State Seventy Holes T-6 Production Facility(COGCC#433001) t4_ Site Location: Site Location SESE, 4N, 6, 62W County: Weld 40.33549, -104.363 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 t 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. 431114 COLORADO Permit Number: 14WE0328 AIRS ID Number: 123 /9BF4/006 Section 2 - Requested Action 0 NEW permit OR newly-reported emission source 0 Request coverage under construction permit ❑ 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- 0 MODIFICATION to existing permit (check each box below that applies) 0 Change fuel or equipment 0 Change company name3 ❑Q Change permit limit 0 Transfer of ownership4 O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- El Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info ft Notes: Requesting new throughput and emission limits using 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: Truck loadout used to loadout condensate offsite. Company equipment Identification No. (optional): TL For existing sources, operation began on: 11/11/2013 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) ❑ 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 annual 0 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 0 No ICC COLORADO drystrtanen.a vm.r Permit Number: 14WE0328 AIRS ID Number: 123 /9BF4/006 Section 4 - Process Equipment Information Product Loaded: 0 Condensate 0 Crude Oil 0 Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 109,500 bbl/year Actual Volume Loaded: 109,500 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: bbl/year Actual Volume Loaded: 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) 40.33549,-104.363 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) ('t7 (ACFM) (ft/sec) ECD 01-06 -25 500 TBD TBD Indicate the direction of the stack outlet: (check one) 0 Upward 0 Downward 0 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): iota* COLORADO MEP VIff peal. En.r nme Hwm u u..,,.n,..,n Permit Number: 14WE0328 AIRS ID Number: 123 /9BF4/006 /006 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. 0 Loading occurs using a vapor balance system: Requested Control Efficiency: 100 % Used for control of: VOC,HAPs Rating: 0.05 MMBtu/hr Combustion Type: Enclosed Combustor Make/Model: Six(6)LEED L30-0010 ElDevice: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 % Minimum Temperature: 500 'F Waste Gas Heat Content: 2,424 Btu/scf Constant Pilot Light: O Yes El No Pilot Burner Rating: N/A MMBtu/hr Pollutants Controlled: ❑ 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? 0 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 SO. NO,, CO VOC EGO 100 95 HAPs ECD 100 95 Other: Ei Using State Emission Factors(Required for GP07) VOC Benzene n-Hexane ❑Q Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL O Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source: Requested Annual Permit Emission Factor Actual Annual Emissions 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/ ear tons/ ear (tons/year)) (tons/year) ) PM 40.0 ug/L AP-42 0.003 0.003 0 003 0 003 SOx 0.00024 Ib/MMEtu AP-42 <0.001 <0.001 <0.001 <0 001 NOx 0.068 Ib/MMBtu AP-42 0.017 0017 0.017 0.017 CO 0.310 Ib/MMBtu AP-42 0 074 0.074 0.074 0.074 VOC 0.236 lb/bbl State EF }2.95 12.9 0.65 12.95 12.9 0.65 5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider EJC per future process growth. Requested values are required on all APENs,including APEN updates. email rec'd 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide 1 Q,28�202a projected emissions. as COIORaDo d wur Permit Number: 14WE0328 AIRS ID Number: 123 /9BF4/006 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-41, Emissions Emissions6 Number Mfg.,etc.) (lbs/year) (lbs/year) Benzene 71432 0 00041 lb/bbl State EF De Minimis De Minimis Toluene 108883 N/A N/A N/A N/A NIA 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 IbIbbl State EF 394 20 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. 62441.'i 1-- - 5/04/2020 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: El 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 5191.13 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 �r�:,„ Gas Venting APEN - Form APCD-211 0 C 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 wilt 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: 14WE0328 AIRS ID Number: 123 I 9BF4 /010 . r Section 1 -Administrative Information Company Name': Bonanza Creek Energy Operating Company,LLC(BCEOC) Site Name: State Seventy Holes T-6 Production Facility(COGCC#433001) Site Location Site Location: SESE, 4N, 6, 62W Weld County: 40.33549, -104.363 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. 431115 1 ®-Deportment MU".i a D COLOR4DO N i nwronMa Permit Number: 14WE0328 AIRS ID Number: 123 /9BF4/O 1 O Section 2 - Requested Action O NEW permit OR newlyareported emission source -OR- ✓❑ MODIFICATION to existing permit (check each box below that applies) 0 Change fuel or equipment 0 Change company name3 0 Add point to existing permit 0 Change permit limit ❑ 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 Et Notes: Requesting new throughput and emission limits. 3 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. '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: Three (3) high/low pressure separators controlled by six (6) enclosed combustors. Company equipment Identification No. (optional): Sep-1 , 2, 3 For existing sources, operation began on: 11/11/2013 For new, modified, or reconstructed sources, the projected start-up date is: ✓❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Wilt this equipment be operated in any NAAQS nonattainment area? Q Yes 0 No Is this equipment located at a stationary source that is considered a Major Source of(HAP) Emissions? ❑ Yes No Is this equipment subject to Colorado Regulation No. 7, 0 Yes ❑ No Section XVII.G? L� COLORADO Permit Number: 14WE0328 AIRS ID Number: 123 /9BF4/010 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? 0 Yes 0 No Vent Gas 2 078 BTU/SCF Gas Venting Heating Value: , Process Parameters5: Requested: 12 MMSCF/year Actual: 12 MMSCF/year -OR- Liquid Throughput Requested: bbl/year Actual: bbl/year Process Parameters5: Molecular Weight: 36.5 voC (Weight%) 65.3656 Benzene (Weight%) 0.2292 Vented Gas Toluene(Weight%) 0.1724 Properties: Ethylbenzene(Weight%) 0.0154 Xy(ene(Weight%) 0.0622 n-Hexane(Weight%) 1.4518 2,2,4-Trimethylpentane(Weight%) 0.0009 Additional Required Documentation: 0 Attach a representative gas analysis(including BTEX a 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(imitations 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. g® COLORADO e c��h.a.tiu Permit Number: 1 4WE0328 AIRS ID Number: 1 23 /9BF4/010 Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.33549,-104.363 O 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. Discharge Height Operator Temp. Flow Rate Velocity Above Ground Level _ Stack Ili No. en (ACFM) (ft/sec) (Feet) ECD 01-06 —25 500 TBD TBD Indicate the direction of the stack outlet: (check one) 0 Upward ❑ Downward O Upward with obstructing raincap ❑ Horizontal ❑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): 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: Size: Make/Model: ❑ VRU: Requested Control Efficiency: VRU Downtime or Bypassed: Pollutants Controlled: VOC, HAPs Rating: 2.85 MMBtu/hr Type: Enclosed Combustor Make/Model: Six(6) Leed L30-0010 ❑ Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: 500 Waste Gas Heat Content: 2,078 Btu/scf Constant Pilot Light: ❑ Yes ✓❑ No Pilot burner Rating: N/A MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: COLORADO n...n,,,..ndnwr r Permit Number: 14WE0328 AIRS ID Number: 123 i 9BF4/010 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? 0 Yes 0 No I 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 NO. CO VOC ECD 100 95 HAPs ECD 100 95 Other: From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source: 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-42 016 016 0.16 0.16 SOx <0.001 Ib/MMBtu AP-42 <0.001 <0.001 <0.001 <0.001 NO„ 0.068 Ib/MMBtu AP-42 085 0.85 0.85 0.85 CO 0.310 Ib/MMBtu AP-42 3.87 3.87 3.87 3.87 VOC 62.933.79 Ib/MMscf Gas Analysis 377 61 18.89 377.61 18.89 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 I Does the emissions source have any uncontrolled actual emissions of non-criteria Yes ❑No i 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 Abstract Source Uncontrolled Controlled Chemical Name Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions6 Basis Mfg.,etc.) (lbs/year) Number (lbs/year) Benzene 71432 22067 lb/MMact lb/bbl 2.650 134 l Toluene 108883 16599 Ib/MMscf lb/bbl 1,992 100 Ethylbenzene 100414 14 83 Ib/MMscf Ib/bbl De Minimis De Minimis Xylene 1330207 59.89 lb/MMscf lb/bbl 720 36 n-Hexane 110543 1,39779 Ib/MMscf lb/bbl 16,774 840 2,2,4-Trimethylpentane 540841 0.87 Ib/MMscf lb/bbl De Minimis De Minimis Other: 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. COLORADO oea,e.u.n.td - MWth 6 Enntanmera Permit Number: 1 4WE0328 AIRS ID Number: 123 i 9BF4/010 Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. a �y 5/04/2020 Signature of Legally Authorized Person (not a vendor or consultant) Date Alisson Soehner Environmental Engineer, Air Quality Name (print) Title Check the appropriate box to request a copy of the: Q Draft permit prior to issuance ❑r 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 go coiosa o0 Hello