HomeMy WebLinkAbout20201949.tiff a. , COLORADO
Y±11 Department of Public
`°'"E Health b Environment
Weld County - Clerk to the Board
1150 O St RECEIVED
PO Box 758
Greeley, CO 80632 MAY 0 8 2020
May 4, 2020 WELD COUNTY
COMMISSIONERS
Dear Sir or Madam:
On May 5, 2020, the Air Pollution Control Division will begin a 30-day public notice period for
Bonanza Creek Energy Operating Company, LLC - North Platte 24-34. A copy of this public notice and
the public comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
<v p
4300 Cherry Creek Drive S.,Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe ( "f
Jared Polls, Governor I Jill Hunsaker Ryan,MPH, Executive Director I �� a R *i,
P4ib 1.c Rev;eCZ CC i.krq L(-K) PW(Sh/Est/cH/cu) 2020-1949
7/O6/2O
6/29/A0
Mc., Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
C.M
CDPHE
Comment
Website Title: Bonanza Creek Energy Operating Company, LLC - North Platte 24-34 - Weld County
Notice Period Begins: May 5, 2020
Notice is hereby given that an application for a proposed projector activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: Bonanza Creek Energy Operating Company, LLC
Facility: North Platte 24-34
Oil and gas well production facility
SESW Sec 34, T5N, R63W
Weld County
The proposed project or activity is as follows: Applicant is requesting modification to an existing facility
with additional throughput from two (2) new wells. In addition applicant is requesting to increase the
control efficiency claimed from an enclosed combustor controlling separator gas.
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 12WE3163 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:
Bradley Eades
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
(COLORADO
1 I Department of Public
Health @ Environment
c�PNE Condensate Storage Tank(s) APEN
'� Form APCD-205
CO ,y`," 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 fore new filing fee.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category,there may be a more specific APEN available for your source(e.g.
crude oil storage tanks,produced water storage tanks, hydrocarbon liquid loading,etc.). In addition, the General
APEN(Form APCD-2OO)is available if the specialty APEN options will not satisfy your reporting needs.A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division(APCD)
website at:www.cotorado.gov[pacifictcdphe/air-permits.
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: 12VVE3163 AIRS ID Number: 123 /9A82"001
Section 1 -Administrative Information
Company Name': Bonanza Creek Energy Operating Company,LLC
Site Name: North Platte 24-34 Production Facility(COGCC#428267)
Site Location
Site Location:
SESW, SEC 34, T5N, R63W County: Weld
40.34915, -104.42346
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip lode 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 alt 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.rA,, 421691
r
,i-tom
AVeoiapAao
Permit Number: 12WE3163 AIRS ID Number: 123 /9A82/001
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 O GPO8
if General Permit coverage is requested,the General Permit registration fee of$312.50 must be
submitted along with the APEN filing fee.
-OR-
❑Q MODIFICATION to existing permit(check each box below that applies)
❑ Change in equipment O Change company name3
Q Change permit limit O Transfer of ownership4 O Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
• APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info&Notes: Updating to include additional throughput from new wells.
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: Eight (8) 800 bbl condensate storage tanks
Company equipment Identification No. (optional): CNDTK-01
For existing sources,operation began on: 08/31/2012
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
Storage tank(s)located at: [3 Exploration&Production(E&P)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? 0 Yes O No
Es the actual annual average hydrocarbon liquid throughput a 500 bbl/day? ❑ Yes O No
If"yes", identify the stock tank gas-to-oil ratio: 0.002 m3/titer
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) ❑ Yes Q No
805 series rules?If so,submit Form APCD-105.
Are you requesting a 6 ton/yr VOC emissions(per storage tank), or are uncontrolled actual ❑ Yes Q Na
emissions.≥6 ton/yr(per storage tank)?
CO LO ADD
Permit Number: 12WE3163 AIRS ID Number: 123 I 9A82/001
Section 4 - Storage Tank(s) information
Actual Annual Amount Requested Annual Permit Limits
(bbl/year) (bbl/year)
Condensate Throughput: 328,500 410,625
Pf°' e°2019
From what year is the actual annual amount?
Average API gravity of sates oil: 43.9 degrees RVP of sales oil: 8.5
Tank design: j Fixed roof O Internal floating roof O External floating roof
Storage #of Liquid Manffold Storage Total Volume of Installation Date of Most Date of First
Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production
(bbl) Storage Tank(month/year) (month/year)
CNDTK 01.08 Eight(8)800 bbl 6400 10/2014 08/2012
Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only)
API Number Name of Well Newly Reported Well
See attached APCD Form 212 O
- O
O
O
- - O
5 Requested values will become permit limitations. Requested limit(s)should consider future growth.
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-Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.34915, -104.42346
Operator Stack Discharge Height Above Temp. Flow Rate Velocity
ID No. Ground Level(feet) (°F) (ACFM) (ft/sec)
ECD 01-06 —8 500 TBD TBD
Indicate the direction of the stack outlet: (check one)
Q Upward O Downward O Upward with obstructing raincap
❑Horizontal 0 Other(describe):
indicate the stack opening and size:(check one)
Q Circular Interior stack diameter(inches): 48
❑Square/rectangle Interior stack width(inches): interior stack depth(inches):
❑Other(describe):
AvGOtOFw6
Permit Number: 12WE3163 AIRS ID Number: 123 /9A82/001
Section 6-Control Device Information
O Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section.
Pollutants Controlled:
Vapor Size: Make/Model:
O Recovery
Unit(VRU): Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented):
Pollutants Controlled: VOC, HAPs
Rating: 1.49 MMBtu/hr
Type: Enclosed Flare Make/Model:(1)Cimarron 48"HV(5)LEED L30-0011
El Combustion Requested Control Efficiency: 95
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: 500 Waste Gas Heat Content: 2,748 Btu/scf
Constant Pilot Light: Q Yes O No Pilot Burner Rating: 0.05 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 (E&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —2 psig
Describe the separation process between the well and the storage tanks:
Well produces to a HP/LP separator where condensate is separated from gas and water.
Condensate from the LP separator is sent to the Vapor Recovery Tower(VRT)where further separation occurs.
Condensate from the VRTs is sent directly to storage tanks.
Permit Number: 12WE3163 AIRS ID Number: 123 /9A82/001
,,, u a.4 ess t (D ;:'rr a ;sisn d pe i i . Di._!A z S,DI
Section 8 Emissions inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form7.
If multiple emission control methods were identified in Section 6,the following table can be used to state the
overall(or combined)control efficiency(%reduction):
Overall Requested Control
Pollutant Description of Control Method(s) Efficiency
(%reduction in emissions)
VOC ECG 95%
NOx
CO
HAPs EGO 95%
Other:
From what year is the following reported actual annual emissions data? 201 9
Criteria Pollutant Emissions Inventory
Emission Factor Actual Annual Emissions Requested Annual Permit
Emission Limit(s
Pollutant )5 Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled
Basis Units (AP-42, Emissions Emissionsa Emissions Emissions
Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) -B.E.Per
email
VOC 1.24 lb/bbl ProMax 204.39 10.22 255.49 12.78 03-24-20
N0x 0.068 Ib/MMBtu AP-42 0.36 0.36 0-:45 0.51 945 0.51(attached)
CO 0.310 lb/MMBtu AP-42 1.64 1.64 2.03 2.34 2.03 2.34
Non-Criteria Reportable Pollutant Emissions Inventory
Chemical Emission Factor Actual Annual Emissions
Chemical Name Abstract Source Uncontrolled Controlled
Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions®
Number Basis Mfg.,etc.) (pounds/Year) (pounds/year)
Benzene 71432 0.0032 lb/bbl ProMax 1,036 52
Toluene 108883 0.0027 lb/bbl ProMax 899 45
Ethylbenzene 100414 0.00022 Ib/bbI ProMax De Minimis De Minimis
Xylene 1330207 0.00077 lb/bbl ProMax 254 13
n-Hexane 110543 0.024 lb/bbl ProMax 7,858 393
2,2,4- 540841 0.000062 lb/bbl ProMax De Minimis De Minimis
Trimethylpentane
5 Requested values will become permit limitations. Requested limit(s)should consider future growth.
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 emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave
blank.
AY COLORADO
Fotm APED 05 ' ncie sa;'e Sri); 2e a Tani,, s1 APE:4 Rev'sfon 3 2019 5 I
Permit Number: 12WE3163 AIRS ID Number: 123 /9A82/001
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 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.
Signature of Legally Authorized Person(not a vendor or consultant) Date
Atisso i Soehner Environmental Engineer,Air Quality
Name(print) Title
Check the appropriate box to request a copy of the:
Ej Draft permit prior to issuance
Q Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration
of the five-year term,or when a reportable change is made(significant emissions increase,increase production,
new equipment, change in fuel type,etc.).See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with$191.13 and the General Permit For more information or assistance call:
registration fee of$312.50, if applicable,to:
Small Business Assistance Program
Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148
Air Pollution Control Division
APCD-SS-B1 APCD Main Phone Number
4300 Cherry Creek Drive South (303)692-3150
Denver,CO 80246-1530
Make check payable to: Or visit the APCD website at:
Colorado Department of Public Health and Environment https://www.cotorado.govicdpheiapcd lay,a,. .;;`�+._ >..I. __ ?-�9'l' ., e-' `.'Yt5'.,, t 6 t«,l, COLOR ..,
ADO
E&P Storage Tank Air Pollutant Emissions Notice(APEN)Addendum Form'
Company Name: Bonanza Creek Energy Operating Company
Source Name: North Platte 24-34
Emissions Source AIRS ID2: 123/9A82/001
Wells Services by this Storage Tank or Tank Battery(E&P Sites Only)
API Number Name of Well Newly Reported Well
05-123-39909 North Platte 14-11-3411C ❑
05-123—39912 North Platte 14-11-34HNB 0
05-123-35297 North Platte 33-34 ❑
05-123-35300 North Platte 34-34 ❑
05- 123-39908 North Platte E-A-34HC 0
05-123-39911 North Platte E-A-34HNB ❑
05-123-39910 North Platte E14-Al 1-34HNB ❑
05-123-35294 North Platte J-F-3411C ❑
05-123-35292 North Platte J-F-34HNB 0
05-123.35298 North Platte J14-F11-34HNC 0
05-123-47956 Park U-4-9XRLNC
05-123-47957 North Platte E-Y-34HNB
0
- - ❑
0
0
0
0
- ❑
Footnotes:
I Attach this addendum to associated APEN form when needed to report additional wells.
2 If this is a newly report source that has not been assigned an AIRS ID by the APCD,enter
N/A
Form APCD-212 APCD-212-EP-StorageTank-APEN-Addendum.docx
a P H E Hydrocarbon Liquid Loading APEN
'1` Form APCD-208
CO to` Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is
filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require
payment for a new filing fee.
This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category,
there may be a more specific APEN for your source(e.g. amine sweetening unit,glycol dehydration unit,
condensate storage tanks,etc.). In addition, the General APEN(Form APCD-200)is available if the specialty APEN
options wilt not satisfy your reporting needs.A list of all available APEN forms can be found on the Air Pollution
Control Division(APCD)website at:www.colorado.gov/cdpheiapcd.
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: 12WE3163 AIRS ID Number: 123 / 9A82/ 002
Section 1 -Administrative Information
Company Name: Bonanza Creek Energy Operating Company,LLC
Site Name: North Platte 24-34 Production Facility(COGCC#428267)
Site Location
Site Location:
SESW, SEC 34, T5N, R63W County: Weld
40.34915, -104.42346
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 alt documents issued by the APCD.Any changes wilt require additional paperwork.
2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
42.1693
Permit Number: 12WE3163 AIRS ID Number: 123 /9A82 i 002
Section 2 - Requested Action
O NEW permit OR newly-reported emission source
O Request coverage under construction permit O 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-
Q MODIFICATION to existing permit(check each box below that applies)
❑ Change fuel or equipment O Change company name3
Q Change permit limit O Transfer of ownership's 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&Notes: Updating to include additional throughput from new wells.
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 truck condensate from site.
Company equipment Identification No. (optional): L-01
For existing sources,operation began on: 08/31/2012
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area? r❑ Yes O No
Is this equipment located at a stationary source that is considered a Major Source of(HAP) ❑ Yes 0 No
emissions?
Does this source toad gasoline into transport vehicles? O Yes r❑ No
Is this source located at an oil and gas exploration and production site? Q Yes O No
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual 0 Yes O No
average?
Does this source splash fill less than 6750 bbl of condensate per year? Q Yes O No
Does this source submerge fill less than 16308 bbl of condensate per year? ❑ Yes ❑r No
COLORADO
Permit Number: 12V1/E3163 AIRS ID Number: 123 /9A82/002
Section 4- Process Equipment Information
Product Loaded: ✓❑ Condensate O Crude Oil O Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loadeds: 410,625 bbl/year Actual Volume Loaded: 410,625 bbt/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 G A F
0.6 bulk liquid-loading: Off
True Vapor Pressure: Psia C 60 `F Molecular weight of 51 .20 tb/lb-mot
7.9 11 displaced vapors:
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Loader's: N/A bbl/year Actual Volume Loaded: NIA bbl/year
Product Density: N/A lb/ft3
Load Line Volume: N/A ft3/truckload Vapor Recovery Line Volume: NA ft3/truckload
5 Requested values will become permit limitations.Requested timit(s)should consider future process growth.
Ayc,ioe °a
Permit Number: 12WE3163 AIRS ID Number: 123 /9A82/002
ta :._. ,F,c.,
Section 5 -Stack Information
Geographical Coordinates
{Latitude/Longitude or UTM)
40,34915, -104.42346
er toe Telxip .e: Rate e
# fie
ck I� � ) 01/x) .:
ECD 01-06 -8 500 TBD TBD
Indicate the direction of the stack outlet: (check one)
Q Upward O Downward O Upward with obstructing raincap
❑Horizontal ❑Other(describe):
Indicate the stack opening and size: (check one)
✓❑Circular Interior stack diameter(inches): 48
❑Other(describe):
Section 6 -Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
❑ Loading occurs using a vapor balance system: Requested Control Efficiency:
Used for control of: VOC,HAPs
Rating: (125 MMBtu/hr
Type: Enclosed Flare Make/Model:(1)Cimarron 48"Hv(5)LEER Lao-aot 1
Combustion
® Device: Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: 500 `F Waste Gas Heat Content: 2,956 Btu/scf
Constant Pilot Light: 0 Yes ❑ No Pilot Burner Rating: 0.05 MMBtu/hr
Pollutants Controlled:
❑ Other: Description:
Requested Control Efficiency:
aY'.. e_ € F1. .-riJ. ., ri i,t x � f�. v § - `3
,
Permit Number: 12WE3163 AIRS iD Number: 123 /9A82/002
__._--.---
Section 7- Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall(or combined)control efficiency(a reduction):
Overall Requested
Pollutant Description of Control Method(s) Control Efficiency
(%reduction in emissions)
PM
SOx
NOx
CO
VOC ECD 95%
HAPs ECD 95%
Other:
❑ Using State Emission Factors(Required for GP07) VOC Benzene n-Hexane
❑Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL
❑Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL
From what year is the following reported actual annual emissions data? 2019
Criteria Pollutant Emissions Inventory
Requested Annual Permit
Emission Factor Actual Annual Emissions Emission Limit(s)5
Pollutant .
Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled
Basco Units (AP-42, Emissions Emissions6 Emissions Emissions
Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year)
PM 40.0 ug/I AP-42 0.0098 0.0098 0.0098 0.0098
SOx 0.00019 Ib/MMBtu AP-42 <0.0001 <0.0001 <0.0001 <0.0001
NOx 0.068 lb/MMBtu AP-42 0.075 0.075 0.075 0.075
CO 0.310 Ib/MMBtu AP-42 0.34 0.34 0.34 0.34
VOC 0.219 Ib/bbl Site Specific 45.04 2.26 45.04 2.26
Non-Criteria Reportable Pollutant Emissions Inventory
Chemical Emission Factor Actual Annual Emissions
Abstract
Chemical Name Service(CAS) Uncontrolled Source Uncontrolled Controlled
Units
Number Basis (AP 42, Emissions Emissions
Mfg.,etc.) (pounds/year) (pounds/year)
Benzene 71432 0.00030 Ib/bbl Site Specific De Minimis De Minimis
Toluene 108883 0,00020 Ib/bbl Site Specific De Minimis De Minimis
Ethylbenzene 100414 <0.0001 Ib/bbl Site Specific De Minimis De Minimis
y
Xylene 1330207 <0.0001 Ib/bbl Site Specific De Minimis De Minimis
n-Hexane 110543 0.0042 ib/bbl Site Specific 1.766 90
2,2,4-
540841 <0.0001 Ib/bbl Site Specific De Minimis De Minimis
Trimethylpentane
Other:
5 Requested values wilt become permit limitations.Requested limits)should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave
blank.
I
Ay CCIOWa.DO
Permit Number: 12WE3163 AIRS ID Number: 123 /9A82/002
r ._' ACC_
Section 8 - 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 wilt be operated in full compliance with each condition of General Permit GP07.
agA30)4--"' . ;tekrcL /1.5
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
0 Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration
of the five-year term,or when a reportable change is made(significant emissions increase,increase production,
new equipment,change in fuel type,etc.).See Regulation No. 3, Part A, II.C.for revised APEN requirements.
Send this form along with$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 or(303)692-3148
Air Pollution Control Division
APCD-SS-B1 APCD Main Phone Number
4300 Cherry Creek Drive South (303)692-3150
Denver,CO 80246-1530
Make check payable to: Or visit the APCD website at:
Colorado Department of Public Health and Environment https://www.colorado.eovtcdphetapcd
BrCOLORADO
c O P H E Produced Water Storage Tank(s)
' ` APEN -- Form APCD-207
CO q Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is
filled out incorrectly, is missing information,or lacks payment for the filing fee. The re-submittal will require
payment for a new filing fee.
This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source(e.g.
crude oil storage tanks,condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN
(Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division(APCD)
website at:www.colorado.gov/pacific/cdphelair-permits.
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, lI.C.for revised APEN requirements.
Permit Number: 12WE3163 AIRS iD Number. 123 /9A82/010
Section 1 Administrative Information
Company Name: Bonanza Creek Energy Operating Company,LLC
Site Name: North Platte 24-34 Production Facility(COGCC#428267)
Site Location
Site Location:
SESW, SEC 34, T5N, R63W County: Weld
40.34915, -104.42346
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
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 additionaipapirwork.
2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
421692
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Permit Number: 12WE3163 AIRS ID Number: 123 /9A82 I 010
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 GP05 0 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-
O MODIFICATION to existing permit(check each box below that applies)
O Change in equipment O Change company name3
Q Change permit limit 0 Transfer of ownership' 0 Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADOrnONAL PERMIT ACTIONS-
El APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info Ft Notes: Updating to include additional throughput from new wells.
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: Two (2) 800 bbl produced water storage tanks
Company equipment Identification No. (optional): PWT-01
For existing sources,operation began on: 08/31/2012
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
Storage tank(s)located at: Q Exploration&Production(MP)site 0 Midstream or Downstream(non E&P)site
Will this equipment be operated in any NAAQS nonattainment area? El Yes 0 No
Are Flash Emissions anticipated from these storage tanks? ✓❑ Yes O No
Are these storage tanks located at a commercial facility that accepts oil production 0 Yes El No
wastewater for processing?
Do these storage tanks contain less than 1%by volume crude oil on an annual average basis? Q Yes 0 No
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) ❑ Yes ❑✓ 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 0 Yes p No
emissions≥6 ton/yr(per storage tank)?
A® cocoa•oo
Permit Number: 12VVE3163 AIRS ID Number: 123 /9A82/010
Section 4- Storage Tank(s) InformationActual Annual Amount Requested Annual Permit Limits
(bbl/year) (bbllyeor)
Produced Water Throughput: 233,600 292,000
P"ected 2019
From what year is the actual annual amount?
Tank design: ❑✓ 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)
Poi 01-02 Two(2)800 bbl 1600 10/2014 08/2012
Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only)
API Number Name of Well Newly Reported Well
• See attached APCD Form 212 O
O
OO
..... _.... .......
5 Requested values will become permit limitations.Requested limit(s)should consider future growth.
6 The EaP Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5-Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.34915, -104.42346
Operator Stack Discharge Height Above Temp. Flow Rate Velocity
ID No. Ground Level(feet) (°F) (ACFM) (ft/sec)
ECD 01-06 -8 500 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)
0 Circular Interior stack diameter(inches): 48
❑Square/rectangle Interior stack width(inches): Interior stack depth(inches):
O Other(describe):
,_ Al/j��
a COLORADO
Permit Number: 12WE3163 AIRS ID Number: 123 /9A82/010
Section 6 Control Device Information
O Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section.
Pollutants Controlled:
Vapor Size: Make/Model:
O Recovery
Unit(VRU): Requested Control Efficiency:
VRU Downtime or Bypassed(emissions vented): %
Pollutants Controlled: VOC, HAPs
Rating: 0.03 MMBtu/hr
Type Enclosed Flare Make/Model:(1)Cimarron 48"HV(5)LEED Lao-0011
❑ Combustion Requested Control Efficiency: 95
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: 500 Waste Gas Heat Content: 971 Btu/scf
Constant Pilot Light: Q Yes O No Pilot Burner Rating: 0.02 MMBtu/hr
Description of the closed loop system:
❑ Closed Loop System
Pollutants Controlled:
▪ Other: Description:
Control Efficiency Requested: �6
Section 7-Gas/Liquids Separation Technology Information (E&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —50 psig
Describe the separation process between the well and the storage tanks:
Well produces to a HP/LP separator where majority of the water is separated from gas and water.
Condensate from the LP separator is sent to the Vapor Recovery Tower(VRT)where further separation occurs.
The remaining water separated from the condensate in the VRT's is sent directly to storage tanks.
£ =O A
N�� �?� �r F�.'C"�, of Ursa '� C? �=a�t3i �' :;� _ ,.z 4 ; N`.�">�, `.nK».,
Permit Number: 12WE3163 AIRS ID Number: 123 /9A82 f 010
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form7.
If multiple emission control methods were identified in Section 6,the following table can be used to state the
overall(or combined)control efficiency(%reduction):
Overall Requested Control
Pollutant Description of Control Method(s) Efficiency
(%reduction In emissions)
V0C ECo 95%
NOx
CO
HAPs ECo
Other:
From what year is the following reported actual annual emissions data? 2019
Criteria Pollutant Emissions Inventory
Requested Annual Permit
Emission Factor7 Actual Annual Emissions Emission Limit(s)5
Pollutant
Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled
Units (042, Emissions Emissions$ Emissions Emissions
Basis
Mfg.,etc.) (tons/year) (tens/year) (tons/year) (tons/year)
VOC 0.017 lb/bbl Flash Analysis 2.03 0.10 2.54 0.13
NOx 0.000050 Ib/bbl Flash Analysis 0.0058 0.0058 0.0073 0.0073
CO 0.00023 lblbbl Flash Analysis 0.027 0.027 0.033 0.033
Non-Criteria Reportable Pollutant Emissions Inventory
Chemical Emission Factor? Actual Annual Emissions
Chemical Name Abstract Source Uncontrolled Controlled
Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions$
Number BasisMfg.,etc.) (pounds/year) (pounds/year)
Benzene 71432 0.0096 lb/bbl Flash Analysis De Minimis De Minimis
Toluene 108883 0.00057 Ib/bbl Flash Analysis De Minimis De Minimis
Ethylbenzene 100414 0.000032 Ib/bbl Flash Analysis De Minimis De Minimis
Xylene 1330207 0.00010 Ib/bbl Flash Analysis De Minimis De Minimis
n-Hexane 110543 0.00045 lb/bbl Flash Analysis De Minimis De Minimis
2,2,4- 540841 0.00 Ib/bbl Flash Analysis De Minimis De Minimis
Trimethylpentane
5 Requested values will become permit limitations.Requested limit(s)should consider future growth.
7 Attach produced water laboratory analysis,stack test results,and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave
blank.
COtORaDO
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Permit Number: 12WE3163 AIRS ID Number: 123 /9A82/010
Section 9-Applicant Certification
I hereby certify that alt information contained herein and information submitted with this application is complete,
true,and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
ay)avL-sveivtot,i 1 (
Signature of Legally Authorized Person(not a vendor or consultant) Date
Alisson Soehner Environmental Engineer, Air Quality
Name(print) Title
Check the appropriate box to request a copy of the:
0 Draft permit prior to issuance
Q Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term,or when a reportable change is made(significant emissions increase, increase production,
new equipment,change in fuel type,etc.).See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with$191.13 and the General Permit For more information or assistance call:
registration fee of$312.50, if applicable, to:
Small Business Assistance Program
Colorado Department of Public Health and Environment (303)692-3175 or(303)692.3148
Air Pollution Control Division
APCD-SS-B1 APCD Main Phone Number
4300 Cherry Creek Drive South (303)692-3150
Denver,CO 80246-1530
Make check payable to: Or visit the APCD website at:
Colorado Department of Public Health and Environment https://www.colorado.$ov/cdphetapcd
Comet ORADO
E&P Storage Tank Air Pollutant Emissions Notice(APEN)Addendum Form'
Company Name: Bonanza Creek Energy Operating Company
Source Name: North Platte 24-34
Emissions Source AIRS ID2: 123/9A82/010
Wells Services by this Storage Tank or Tank Battery(E&P Sites Only)
API Number Name of Well Newly Reported Well
05-123-39909 North Platte 14-1I-34HC O
05-123—39912 North Platte 14-11-34HNB O
05-123-35297 North Platte 33-34 O
05-123-35300 North Platte 34-34 O
05-123-39908 North Platte E-A-34HC O
05-123-39911 North Platte E-A-34HNB O
05-123-39910 North Platte E14-A11-34HNB O
05-123-35294 North Platte J-F-34HC O
05-123-35292 North Platte J-F-34HNB
05-123-35298 North Platte J14-F1 I-34HNC O
05-123—47956 Park U-4-9XRLNC ►1
05-123-47957 North Platte E-Y-34HNB ►,1
- O
- - O
O-
- 0
0
- - O
_ ❑
Footnotes:
I Attach this addendum to associated APEN form when needed to report additional wells.
2 If this is a newly report source that has not been assigned an AIRS ID by the APCD,enter
N/A
Form APCD-212 APCD-2 12-EP-StorageTank-APEN-Addendum.docx
CDPHE Gas Venting APEN - Form APCD-211
CO y Air Pollutant Emission Notice (AP£N) and
Application for Construction Permit
Ail sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is
filled out incorrectly, is missing information,or lacks payment for the filing fee. The re-submittal will require
payment for a new filing fee.
This APEN is to be used for gas venting only.Gas venting includes emissions from gas/liquid separators, well head
casing, pneumatic pumps, blowdown events,among other events. If your emission unit does not fall into this
category, there may be a more specific APEN for your source(e.g.amine sweetening unit,hydrocarbon liquid
loading,condensate storage tanks, etc.). In addition, the General APEN(Form APCD-200)is available if the
specialty APEN options wilt not satisfy your reporting needs.A list of all available APEN forms can be found on the
Air Pollution Control Division(APCD)website at:www.colorado.$ovicdphetapcd.
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five/ear 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: 12WE3163 AIRS ID Number: 123 /9A82 /013
,c ° +:
Section 1 -Administrative information
Company Name: Bonanza Creek Energy Operating Company.LLC
Site Name: North Platte 24-34 Production Facility(C0GCC#4288267)
Site Location
Site Location: SESW, SEC 34, T5N, R63W Weld
County:
40.34915, -104.42346
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 wilt require additional paperwork.
2 Permits,exemption letters,and any processing invoices wilt be issued by the APCD via e-mail to the address provided.
421694
h� cotou aoo
Permit Number: 12WE3163 AIRS ID Number: 123 /9A82/013
Section 2 - Requested Action
❑ NEW permit OR newly-reported emission source
-OR
❑✓ MODIFICATION to existing permit(check each box below that applies)
0 Change fuel or equipment 0 Change company name3 ❑ Add point to existing permit
❑✓ Change permit limit ❑ Transfer of ownership' O Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info&Notes: Updating to include throughput from new wells.
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: Gas flaring from low pressure separators and vapor recovery tower.
Company equipment Identification No. (optional): LPGFL
For existing sources,operation began on: 8/31/2012
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 hours/day days/week weeks/year
Operation:
Will this equipment be operated in any NAAQS
El Yes O No
nonattainment area?
Is this equipment located at a stationary source that is ❑ yes 0 No
considered a Major Source of(HAP)Emissions?
Is this equipment subject to Colorado Regulation No. 7, Q Yes ❑ No
Section XVII.G?
EYCOIOatAD6
Permit Number: 12WE3163 AIRS ID Number: 123 /9A82/013
Section 4- Process Equipment Information
❑✓ Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model: Serial#: Capacity: gallmin
❑ 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 toy? ❑ Yes O No
Vent Gas 2 97 BTu/sCF
Gas Venting Heating Value:
Process Parameters: Requested: 12 MMSCF/year Actual: 12 MMSCF/year
-OR-
Liquid Throughput
Requested: bbUyear Actual: bbl/year
Process Parameters5•
Molecular Weight: 39.1
VOC(Weight%) 70.81
Benzene(Weight%) 0.13
Vented Gas Toluene(Weight%) 0.1
Properties: Ethylbenzene(Weight%) 0.010
Xylene(Weight%) 0.041
n-Hexane(Weight%) 1.24
2,2,4-Trimethylpentane(Weight%) 0.00070
Additional Required Information:
❑✓ Attach a representative gas analysis(including BTEX it n-Hexane, temperature,and pressure)
❑ Attach a representative pressurized extended liquids analysis(including BTEX Et n-Hexane, temperature,and
pressure)
s Requested values will become permit Limitations.Requested limit(s)should consider future process growth.
//S� Ct71OAADO
Permit Number: 12WE3163 AIRS ID Number: 123 /9A82/013
Section 5 - Stack Information
Geographical Coordinates
(Lotitudettongitude or UTM)
40.34915,-104.42346
Discharge Height
9P!!ra#c Temp. Fiona Rate Velocity.
'7—,77---7.,,r-74!r.level
Stack:ID Ho. (° (ACFhi) ttsec).
{feet}.
ECD-07 -25 500 TBD TBD
Indicate the direction of the stack outlet: (check one)
❑✓ Upward ❑Downward ❑Upward with obstructing raincap
❑Horizontal O Other(describe):
Indicate the stack opening and size: (check one)
✓❑Circular Interior stack diameter(inches): 96
❑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: 3.01 MMBtu/hr
Type: Enclosed Flare Make/Model: One(1) GCO Beast 3200
❑ Combustion Requested Control Efficiency: 98
Device:
Manufacturer Guaranteed Control Efficiency: 99
Minimum Temperature: 500 Waste Gas Heat Content: 2,197 Btu/scf
Constant Pilot Light: Q Yes O No Pilot burner Rating: 0.04 MMBtu/hr
Pollutants Controlled:
O Other: Description:
Requested Control Efficiency:
4
COLD L4DO
Permit Number: 12WE3163 AIRS ID Number: 123 /9A82/013
, e .,t. _. _, E. „ 3z::r.�;
Section 7- Emissions Inventory Information
Attach alt emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall(or combined)control efficiency(%reduction):
Overall Requested
Pollutant Description of Control Method(s) Control Efficiency
(%reduction in emissions)
PM
SOx
NOX
CO
VOC ECD 98%
HAPs ECD 98%
Other:
From what year is the following reported actual annual emissions data? 2019
Criteria Pollutant Emissions Inventory
Requested Annual Permit
Emission Factor Actual Annual Emissions Emission Limit(s)5
Pollutant
Uncontrolled Source UnEontrolied Controlled Uncontrolled Controlled
Basis Units (AP-42, Emissions Emissions° Emissions Emissions
Mfg-,etc.) (tons/year) (tons/year) (tons/year) (tons/year)
PM 40.0 ug/L AP-42 0.16 0.16 0.16 0.16
SOx <0.0001 lb/MMBtu AP-42 <0.0001 <0.0001 <0.0001 <0.0001
NOx 0.068 Ib/MMBtu AP-42 0.90 0.90 0.90 0.90
CO 0.310 iblMMBtu AP-42 4.09 4.09 4.09 4.09
VOC 73,127.46 Ib/MMscf Site Specific 438.77 8.78 438.77 8.78
Non-Criteria Reportable Pollutant Emissions Inventory
Chemical Emission Factor Actual Annual Emissions
Chemical Name Abstract Source Uncontrolled Controlled
(cps)Service( ) Uncontrolled Units (AP-42, Emissions Emissions6
Number Basis Mfg.,etc.) (pounds/year) (pounds/year)
Benzene 71432 137.87 Ib/MMscf Site Specific 1,656 34
Toluene 108883 111.84 Ib/MMscf Site Specific 1,344 28
Ethylbenzene 100414 10.74 IbtMMscf Site Specific De Minimis De Minimis
Xylene 1330207 42.44 Ib/MMscf Site Specific 510 12
n-Hexane 110543 1,275.41 Ib/MMscf Site Specific 15,036 308
2'2'4 540841 0.72 Ib/MMscf Site Specific De Minimis De Minimis
Trimethylpentane
Other:
5 Requested values will become permit limitations.Requested limit(s)should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave
blank.
COlORa 40
Permit Number: 12WE3163 AIRS iD Number: 123 /9A82/013
Section 8 -Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true,and correct.
((5- .1Cf
Signature of Legally Authorized Person(not a vendor or consultant) Date
Alisson Soehner Environmental Engineer,Air Quality
Name(please 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, 11.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 or(303)692-3148
APCD-SS-B1
4300 Cherry Creek Drive South APCD Main Phone Number
Denver,CO 80246-1530 (303)692-3150
Make check payable to: Or visit the APCD website at:
Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/aped
/L� LOLi3A AD4
CDPHE ( COLORADO
T CO I=
Air Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 1 2WE3 1 63 Issuance: 7
Date issued:
Bonanza Creek Energy Operating
Issued to: Company, LLC
Facility Name: North Platte 24-34 Production Facility
Plant AIRS ID: 123/9A82
Physical Location: SESW SEC 34 T5N R63W
County: Weld County
Description: Well Production Facility
Equipment or a vity su• ct P this pe "'t '
"" max,
Facility � Control
AIRS rr` Emissi•�
Equipment ui•� ent D 'pt
Dint , "
.
ID �� Descri• •n
Eight (8) 800 barrel fixed roof storage
CNDTK-01 001 vessels used to store condensate connected Enclosed Flare
via liquid manifold
L-01 002 Hydrocarbon loadout to tanker trucks Enclosed Flare
Two (2) 800 barrel fixed roof storage
PWT-01 010 vessels used to store produced water Enclosed Flare
connected via liquid manifold
Eight (8) low pressure separators and two
LPGFL 013 (2) vapor recovery towers (VRTs) with Enclosed Flare
emissions routed to a dedicated combustor (1-GC0 Beast 3200)
during vapor recovery unit (VRU) downtime
DENY 01 017 One TEG dehydrator equipped with a still Enclosed Flare
vent, flash tank, and reboiler.
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 23
tDPHE COLORADO
CO Air Pollution Control Division
" 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. AIRS Point 013, 017: YOU MUST notify the Air Pollution Control Division (the Division) no later
than fifteen days commencement of operation under this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to
notify the Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the
revocation of the permit.
2. AIRS Point 013, 017: Within one hundred and eighty days (180) of the latter of commencement
of operation or issuance of this permit, compliance with the conditions contained in this permit
must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self-certify
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
3. AIRS Point 013, 017: This permit must expire if the owner or operator of the source for which
this per ued: constr cif .arm � � .,,?eration of this
source the • of issu ce o is cons c ion permit or the
date on ich suc r on uction activ' sche•red to commend as set forth in the
permit a ,lication .o � � '�� w this 'i) di d constr Ltion for a period of
eighteen $onths or or iii) • : not g within a sonable time of the
estimate com• .. , n d g . The , „isi• may g ensions of the „1,-adline. (Regulation
Number ; °. ecti• III.F.4.)
4. AIRS Point 013, 017: The operator must complete all initial compliance testing and sampling
as required in this permit and submit the results to the Division as part of the self-certification
process. (Regulation Number 3, Part B, Section III.E.)
5. AIRS Point 013: Upon commencement of operation, the operator must install a flow meter to
monitor and record volumetric flow rate of natural gas at the inlet to the enclosed
combustion device covered by this permit and for this emission point.
6. AIRS Point 013: Upon commencement of operation, the operator must install equipment
necessary to monitor the enclosed flare pilot system as described in this permit.
7. AIRS Point 017: The following information shall be provided to the Division within fifteen (15)
days of the latter of commencement of operation or issuance of this permit.
• The dehydrator manufacturer name, model number and serial number
• The glycol circulation pump manufacturer name and model number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation Number 3, Part B, III.E.)
8. The operator must retain the permit final authorization letter issued by the Division, after
completion of self-certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
Page 2 of 23
CDPHE COLORADO Co Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
EMISSION LIMITATIONS AND RECORDS
9. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility AIRS Tons per Year Emission
Equipment ID Point PM2.5 NOX VOC CO Type
CNDTK-01 001 0.5 12.8 2.4 Point
L-01 002 --- 0.1 2.3 0.3 Point
PWT-01 010 - - 0.2
LPGFL 013 - - 1.0 8.8 4.1 Point
DEHY-01 017 --- --- 2.1 --- Point
Note: See"Notes to Permit Holder"for r information on emission factors and methods used to calculate limits.
Facility- a emi t}`ins • -ac in t ` •ual h ous air utant mu t n exceed 8.0 tons per
year.
w,rcI Facility- •e emiss w s • •' . ardou tan us not excee• 0.0 tons per year.
The faci -wid issi• limita f azardo ai ollutants must ply to all permitted
emission • ; is fa y
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.
10. AIRS Points 001, 002 , 010, and 013: The owner or operator must use the emission factors and
calculation methods 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.
11. AIRS Point 017: Compliance with the emission limits in this permit shall be demonstrated by
running the GRI GlyCalc model version 4.0 or higher on a monthly basis using the most recent
extended wet gas analysis and recorded operational values, including: gas throughput, lean
glycol recirculation rate, condenser temperature, flash tank temperature and pressure, wet gas
inlet temperature, and wet gas inlet pressure. Recorded operational values, except for gas
throughput, shall be averaged on a monthly basis for input into the model and be provided to
the Division upon request.
12. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Page 3 of 23
CDPHE COLORADO
CO Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
CNDTK-01 001 Enclosed combustors VOC, HAP
L-01 002 Enclosed combustors VOC, HAP
PWT-01 010 Enclosed combustors VOC, HAP
Emissions from the LP Separators and VRT
are commingled and routed to the enclosed
LPGFL 013 combustor during Vapor Recovery Unit (VRU) VOC, HAP
downtime
Make: GCO Model: Beast 3200 SN: TBD
Still Vent: Enclosed combustor VOC, HAP
DEHY- 017
4x
k: 10 jtcycle t ue gas ine • , HAP
13. The own or oper «:r s �' ` e and int the 1;,,q-.points i _ he table below as a
closed 1.j• syste :nd hall = cle -oT ` lss s as describe• . n the table below.
(Regulat: , P B, Sa Il
Facility AIRS Emissions Recycling Description Pollutants
Equipment ID Point Recovered
DEHY-01 017 Flash Tank: 100% recycle to fuel gas VOC, HAP
PROCESS LIMITATIONS AND RECORDS
14. 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 Process Parameter Annual Limit
Equipment ID Point
CNDTK-01 001 Condensate throughput 410,625 barrels
L-01 002 Condensate throughput 410,625 barrels
PWT-01 010 Produced water throughput 292,000 barrels
LPGFL 013 Gas from LP Separators and 12.0 MMscf
VRTs to enclosed combustor
DEHY-01 017 Wet Gas 4380 MMscf
Page 4 of 23
` CDPHE COLORADO
CO Air Pollution Control Division
ry I Department of Pubic Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
15. AIRS Point 013: The owner or operator must continuously monitor and record the volumetric
flow rate of natural gas vented from the LP Separators and VRTs using a flow meter located at
the inlet to the enclosed combustor covered by this permit. The flow meter(s) must be
calibrated and maintained per the manufacturer's specifications and schedule. The owner or
operator shall use monthly throughput records to demonstrate compliance with the process
limits contained in this permit and to calculate emissions as described in this permit.
16. AIRS Point 013: The owner or operator must operate a flame detection system that monitors
the flare pilot system for the presence of a flame. If a flame is not detected, the facility will
emergency shutdown such that the wells cannot produce to the facility.
17. AIRS Point 013: At a minimum of a weekly basis, the owner or operator must monitor the
control device for the presence of a pilot light and an operational auto-igniter. These
monitors shall = �a calculat •ntrol d- tperiods
without pres- of •i o i• :::-;.nd/orb �•perati• au o-igni er, e ow volume from
emission ource(s) `all °!- assign R a 0% effic 4 cy These mo •ring records must
be main ed for -ri• � e ) yea . sum 'onthly e •t light downtime
and vap• low dur pi 1,' ligh�vents =R: prod:•ed to the divisn upon request.
18. AIRS Poi? g vol e of a • bssed shay •e -asured by gas deter or b assumingZR
by
the maximum design rate of the dehydrator unit of 12.0 MMscf/day.
19. AIRS Point 017: This unit must be limited to the maximum lean glycol circulation rate of 3.5
gallons per minute. The lean glycol recirculation rate shall be recorded daily in a log maintained
on site and made available to the Division for inspection upon request. Glycol recirculation rate
shall be monitored by one of the following methods: assuming maximum design pump rate,
using glycol flow meter(s), or recording strokes per minute and converting to circulation rate.
This maximum glycol circulation rate does not preclude compliance with the optimal glycol
circulation rate (Lops) provisions under MACT HH. (Reference: Regulation Number 3, Part B,
II.A.4)
20. AIRS Point 017: On a weekly basis, the owner or operator shall monitor and record operational
values including: flash tank temperature and pressure, wet gas inlet temperature and pressure.
These records shall be maintained for a period of five years.
STATE AND FEDERAL REGULATORY REQUIREMENTS
21. 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)
22. 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
Page 5 of 23
DPHE COLORADO
CO 1% Air Pollution Control Division
Department of Public Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall
have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. a 4.)
23. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
24. AIRS Point 001, 010: This source is subject to Regulation Number 7, Part D, Section I. The
operator must comply with all applicable requirements of Section I and, specifically, must:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for storage tanks; and
• 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)
25. AIRS Point 001, 002, 010, 013: 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 •. •ustio 1 used to , trot • F. compounds to
comply -c :I, i ust •a losed;, ® : no vis - emissions .ur , normal operations,
as defin "un•-r ul. •n Num 7, P®: t � Secti t I I.A.23, and b- esigned so that an
observer •�•n, .y an obse .do rom viti de of - enclosed flare or
combust b eX , her 11. enie .pr. d by the Divisi el, determine whether
it is opera • •t ly. 's flare ast equipp=4wi:Wan operational=_ to-igniter according
to the sc ® y.r Regul. on Numb l'' 'art D, Se yo I.B.2.d.
26. AIRS Point 001, 010: The storage tank covered by this permit is subject to the emission control
requirements in Regulation Number 7, Part D, Section II.C.1. The owner or operator must install
and operate air pollution control equipment that achieves an average hydrocarbon control
efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency
of at least 98% for hydrocarbons except where the combustion device has been authorized by
permit prior to March 1, 2020. The source must follow the inspection requirements of
Regulation Number 7, Part D, Section II.C.1.d. and maintain records of the inspections for a
period of two years, made available to the Division upon request. This control requirement
must be met within 90 days of the date that the storage tank commences operation.
27. AIRS Point 001, 010: 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.
28. AIRS Point 002: Hydrocarbon liquids loadout from storage tanks to transport vehicles must be
controlled by using (a) submerge fill and (b) a vapor collection and return system and/or air
pollution control equipment. Compliance with Section II.C.5. must be achieved in accordance
with the following schedule: (Regulation Number 7, Part D, Section II.C.5.a.)
• Facilities constructed or modified on or after May 1, 2020, must be in compliance by
commencement of operation.
Page 6 of 23
4, CDC COLORADO
CO i Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021.
• Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.5.a.(i)(B) that exceed the
hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal to
5,000 barrels per year on a rolling 12-month basis must control emissions from loadout
upon exceeding the loadout threshold.
29. AIRS Point 002: Storage tanks must operate without venting at all times during loadout.
(Regulation Number 7, Part D, Section II.C.5.a.(ii))
30. AIRS Point 002: The owner or operator must, as applicable (Regulation Number 7, Part D,
Section II.C.5.a.(iii)):
• Install and operate the vapor collection and return equipment to collect vapors during
the loadout of hydrocarbon liquids to tank compartments of outbound transport vehicles
and to route the vapors to the storage tank or air pollution control equipment.
• Include devices to prevent the release of vapor from vapor recovery hoses not in use.
• Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to
tra ••rt vehicles n - s the vapor col.- donan• r rn •s -m i u
• Orllrate a co t .n• • sal eg• ent a back-pressure - s than the pressure
r -f valve . ti •f tr•n t ve
• Tit owner op for tins® lo.1.,ng equipment ',f5 ensure that hoses,
C '•lin•s k• • v. es area yin r ed to P, ve ; dripping, lea , or other liquid or
v-1;%"a ,- • ring :dout. T rspection u 4 •ccur at least ri ithly, unless loadout
occurs less frequently, then as often as loadout is occurring.
31. AIRS Point 002: The owner or operator must perform the following observations and training
(Regulation Number 7, Part D, Section II.C.5.a.(iv)):
• The owner or operator must observe loadout to confirm that all storage tanks operate
without venting when loadout operations are active. These inspections must occur at
least monthly, unless loadout occurs less frequently, then as often as loadout is
occurring,
• If observation of loadout is not feasible, the owner or operator must document the
annual loadout frequency and the reason why observation is not feasible and inspect the
facility within 24 hours after loadout to confirm that all storage tank thief hatches (or
other access point to the tank) are closed and latched.
• The owner or operator must install signage at or near the loadout control system that
indicates which loadout control method(s) is used and the appropriate and necessary
operating procedures for that system.
• The owner or operator must develop and implement an annual training program for
employees and/or third parties conducting loadout activities subject to Section II.C.5.
that includes, at a minimum, operating procedures for each type of loadout control
system.
Page 7 of 23
C°PHE COLORADO
CO Air Pollution Control Division
'" Department of Pubthc Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
32. AIRS Point 002: The owner or operator must retain the records required by Regulation Number
7, Part D, Section II.C.5.a.(v) for at least two (2) years and make such records available to the
Division upon request.
• Records of the annual facility hydrocarbon liquids loadout to transport vehicles
throughput.
• Inspections, including a description of any problems found and their resolution, required
under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log.
• Records of the infeasibility of observation of loadout.
• Records of the frequency of loadout.
• Records of the annual training program, including the date and names of persons
trained.
33. AIRS Point 002: 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. i
34. AIRS Poi 013: Mry sep tor co ,, .-d by -7.'=ermit i =ubject to Regu ion 7, Part D,
Section I A . On or :V -r gust 1 V 4, g. • g offse•arator, pro ed during normal
operatio rom any - ed, h , ly r reco eted oil and gas
well, mu either b- ou • to a gat _ •r c.4 trolled from th ommencement of
operatio �Y,X tio ontrol ; i ;i> o-p � p � nt that - = i- s an average h ocarbon control
efficient If a co ustion d= `is used, i u have a design truction efficiency
of at least 98% for hydrocarbons.
35. AIRS Point 017: This source is subject to Regulation Number 7, Section XII.H. The operator
shall comply with all applicable requirements of Section XII and, specifically, shall:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for glycol natural gas dehydrators; and
• Ensure uncontrolled actual emissions of volatile organic compounds from the still vent
and vent from any gas-condensate-glycol (GCG)separator (flash separator or flash tank),
if present, shall be reduced by at least 90 percent on a rolling twelve-month basis
through the use of a condenser or air pollution control equipment. (Regulation Number
7, Section XII.H.1.)
36. AIRS Point 017: The glycol dehydration unit covered by this permit is subject to the emission
control requirements in Regulation Number 7, Section XVII.D.3. Beginning May 1, 2015, still
vents and vents from any flash separator or flash tank on a glycol natural gas dehydrator located
at an oil and gas exploration and production operation, natural gas compressor station, or gas-
processing plant subject to control requirements pursuant to Section XVII.D.4., shall reduce
uncontrolled actual emissions of hydrocarbons by at least 95% on a rolling twelve-month basis
through the use of a condenser or air pollution control equipment.
37. AIRS Point 017: The combustion device covered by this permit is subject to Regulation
Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other
Page 8 of 23
CDPHE COLORADO
CO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
combustion device is used to control emissions of volatile organic compounds to comply with
Section XVII, it must be enclosed; have no visible emissions during normal operations, as
defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by
means of visual observation from the outside of the enclosed flare or combustion device, or
by other convenient means approved by the Division, determine whether it is operating
properly. This flare must be equipped with an operational auto-igniter according to the
following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto-igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto-igniter by or before May 1, 2016,or after the next combustion device
planned shutdown, whichever comes first.
38. AIRS Point 017: The glycol dehydration unit at this facility is subject to National Emissions
Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas
Production Facilities, Subpart HH. This facility shall be subject to applicable area source
provisio egula in 4i .F.R P.,. ZIAs, (Regulation
Number : •art ; •pa A and 9
115 ,5,11,O5
•
Page 9 of 23
CDPHE COLORADO
Co9 Air Pollution Control Division
1
'" Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
MACT HH Applicable Area Source
Requirements Benzene emissions exemption
§63.764 (e)(1) - The owner or operator is exempt from the
requirements of paragraph (d) of this section if the criteria listed
in paragraph (e)(1)(i) or (ii) of this section are met, except that
the records of the determination of these criteria must be
§63.764 - General maintained as required in §63.774(d)(1).
Standards
§63.764 (e)(1)(ii) - The actual average emissions of benzene from
the glycol dehydration unit process vent to the atmosphere are
less than 0.90 megagram per year, as determined by the
procedures specified in §63.772(b)(2) of this subpart.
§63.772(b) - Determination of glycol dehydration unit flowrate or
benzene emissions. The procedures of this paragraph shall be
used by an owner or operator to determine glycol dehydration
unit natural gas flowrate or benzene emissions to meet the
criteria for an exemption from control requirements under
§6 1 .
§6 72(b) -The a lnatl a of actualaver benzene
e �sions fr b a gly , • w drat '" unit shall be de using the
pr :" eith ,, .ph ( (b)(2)(i of this
77: se eon. E� ions . Ater ned either unc rolled, or
wl ra,federa ceable r tr in place.
§63.772 - Test §63.772(b)(2)(i) - The owner or operator shall determine actual
Methods, average benzene emissions using the model GRI-GLYCaIc TM,
Compliance Version 3.0 or higher, and the procedures presented in the
Procedures and associated GRI-GLYCalc TM Technical Reference Manual. Inputs to
Compliance the model shall be representative of actual operating conditions
Demonstration of the glycol dehydration unit and may be determined using the
procedures documented in the Gas Research Institute (GRI) report
entitled "Atmospheric Rich/Lean Method for Determining Glycol
Dehydrator Emissions" (GRI-95/0368.1); or
§63.772(b)(2)(ii) - The owner or operator shall determine an
average mass rate of benzene emissions in kilograms per hour
through direct measurement using the methods in §63.772(a)(1)(i)
or (ii), or an alternative method according to §63.7(f). Annual
emissions in kilograms per year shall be determined by
multiplying the mass rate by the number of hours the unit is
operated per year.This result shall be converted to megagrams
per year.
Page 10 of 23
CDPHE COLORADO
CO Air Pollution Control Division
Department of Public Health Fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
§63.774 (d)(1) - An owner or operator of a glycol dehydration
unit that meets the exemption criteria in §63.764(e)(1)(i) or
§63.764(e)(1)(ii) shall maintain the records specified in paragraph
§63.774 - (d)(1)(i) or paragraph (d)(1)(ii) of this section, as appropriate, for
Recordkeeping that glycol dehydration unit.
Requirements §63.774 (d)(1)(ii) - The actual average benzene emissions (in
terms of benzene emissions per year) as determined in
accordance with §63.772(b)(2).
OPERATING >:t MAINTENANCE REQUIREMENTS
39. AIRS Point 001, 002, 010, 013, 017: Upon startup of these points, the owner or operator must
follow the most recent operating and maintenance (O&M) plan and record keeping format
approved by the Division, in order to demonstrate compliance on an ongoing basis with the
requirements of this permit. Revisions to the OFtM plan are subject to Division approval prior
to implementation. (Regulation Number 3, Part B, Section IILG.7.)
COMPLIANCE T .(c1E1.. a S•
NV A
rf
Initial T • ye
40. AIRS Po",`,,,* 013: f o er/o• �.for � #x let; n initial site -cific extended gas
analysis nal ithi •ne hu :-d . • eighty'.f:„ ' .0)after comm cement of operation
or issuan _ permi hichev 614 es later, °t commingled ga ented from the Low
Pressure (LP) Separators and Vapor Recovery Towers (VRTs) covered by this permit in order to
verify the VOC content (weight fraction and molecular weight) of this emission stream. Results
of the Analysis must be used to calculate site-specific emission factors for the pollutants
referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods.
Results of the Analysis must be submitted to the Division as part of the self-certification and
must demonstrate the emissions factors established through the Analysis are less than or equal
to, the emissions factors submitted with the permit application and established herein in the
"Notes to Permit Holder"for this emissions point. If any site specific emissions factor developed
through this Analysis is greater than the emissions factors submitted with the permit application
and established in the "Notes to Permit Holder"the operator must submit to the Division within
60 days, or in a timeframe as agreed to by the Division, a request for permit modification to
address these inaccuracies.
41. AIRS Point 013: The owner or operator must conduct an initial source compliance test to
measure the mass emission rates of the pollutants listed below, demonstrate compliance with
the emissions limit in this permit, and to demonstrate a minimum destruction efficiency of 98%
for volatile organic compounds (VOC). During the test, the owner or operator must measure:
• mass emission rates of VOC at the inlet of the control device (M) using EPA or other
division approved methods;
• mass emission rates of VOC at the outlet of the control device (M0) using EPA or other
division approved methods; and
Page 11 of 23
CDPHE COLORADO
Air Pollution Control Division
CO ;-
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• mass emission rates of N0x and CO at the outlet of the control device using EPA or
other division approved methods.
Additionally, the following parameters may be required to be measured during the test:
• combustion chamber temperature;
• gas flow rate;
• supplemental fuel flow rate;
• gas heat content; and
• gas composition.
The destruction efficiency (DE) for V0C must be calculated using the following equation:
DE (%) = 100*(M;-Mo)/Mi
The test protocol, test, and test report must be in accordance with the requirements of the
Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to
the Division for review and approval at least thirty (30) days prior to testing. No compliance
test will be conducted without prior approval from the Division. Within thirty (30) days
following completion of the test(s), a compliance test report must be submitted to the
Division + h7r Addi c..!4", may be nted up•+ 4 r !, „ ompliance
test con sl e• mo ra e c• .(I fiance a mon Y"o annua e on mitation shall
have thel-sults pr•lj-ct up to t . ont . nnual eraging time b ultiplying the test
results b he Proc Li 'I at av- in ime ,,1" 104-d in th 'rocess Limitations
and Rec., per 1,
s sectio��f t ` � , (Re�` �-�� � b C' Part B., Sect III.G.3)
Results 44:4 co iance te' � st be sub%i ,t:5': to the Division`s. part of the self-
certification. Actual emissions calculations must be completed in accordance with PS Memo
20-02.
42. AIRS Point 017: The owner or operator shall demonstrate compliance with opacity standards,
using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or
absence of visible emissions. "Visible Emissions" means observations of smoke for any period
or periods of duration greater than or equal to one minute in any fifteen minute period during
normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16)
43. AIRS Point 017: The owner or operator shall complete the initial extended wet gas analysis
within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit. The owner or operator shall use this analysis to calculate actual
emissions, as prescribed in the Emission Limitation and Records section of this permit, to verify
initial compliance with the emission limits. The owner or operator shall submit the analysis and
the emission calculation results to the Division as part of the self-certification process.
(Reference: Regulation Number 3, Part B, Section III.E.)
Periodic Testing Requirements
44. AIRS Point 013: On a semi-annual basis, the owner/operator must complete a site specific
extended gas analysis ("Analysis") after commencement of operation or issuance of this permit,
whichever comes later, of the commingled gas vented from the Low Pressure (LP) Separators
and Vapor Recovery Towers (VRTs) covered by this permit to verify the V0C content (weight
fraction and molecular weight) of this emission stream. Results of the Analysis must be used to
Page 12 of 23
91/4CDPHE COLORADO
CO Air Pollution Control Division
'" I Department of Pubi e Health ft Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
calculate site-specific emission factors for the pollutants referenced in this permit (in units of
lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must be
submitted to the Division as part of the self-certification and must demonstrate the emissions
factors established through the Analysis are less than or equal to, the emissions factors
submitted with the permit application and established herein in the "Notes to Permit Holder"
for this emissions point. If any site specific emissions factor developed through this Analysis is
greater than the emissions factors submitted with the permit application and established in the
"Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a
timeframe as agreed to by the Division, a request for permit modification to address these
inaccuracies.
No Analysis may be conducted less than ninety (90) days subsequent to any Analysis used to
demonstrate compliance with this requirement.
45. AIRS Point 013: On an annual basis, the owner or operator must conduct a source compliance
test to measure the mass emission rates of the pollutants listed below, demonstrate compliance
with the emissions limit in this permit, and to demonstrate a minimum destruction efficiency
of 98% for volatile organic compounds (VOC). During the test, the owner or operator must
measure:
• s _ i ra • -.1, the i the c ro •evlceing PA or other
d 7 ion app ed th••s• .x
• s emissi'Ara the tl t a the i -vice ( l using EPA or other
d ion app : ed ethos •no
• s em' rat.:, of NO d at the ya ft le f the control d ce using EPA or
o y on ap• A ved met '4'• :Q
Additionally, the following parameters may be required to be measured during the test:
• combustion chamber temperature;
• gas flow rate;
• supplemental fuel flow rate;
• gas heat content; and
• gas composition.
The destruction efficiency (DE) for VOC must be calculated using the following equation:
DE (%) = 100*(M;-Mo)/M;
The test protocol, test, and test report must be in accordance with the requirements of the
Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to
the Division for review and approval at least thirty (30) days prior to testing. No compliance
test will be conducted without prior approval from the Division. Within thirty (30) days
following completion of the test(s), a compliance test report must be submitted to the
Division for review. Additional time may be granted upon written request. Any compliance
test conducted to demonstrate compliance with a monthly or annual emission limitation shall
have the results projected up to the monthly or annual averaging time by multiplying the test
results by the Process Limit(s) for that averaging time as indicated in the Process Limitations
and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3)
Page 13 of 23
cDPHE COLORADO
CO Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Records of the annual compliance tests must be maintained by the owner or operator and
made available to the Division for inspection upon request. Actual emissions calculations
must be completed in accordance with PS Memo 20-02.
46. AIRS Point 017: The owner or operator shall complete an extended wet gas analysis prior to
the inlet of the dehydration unit on an annual basis. Results of the wet gas analysis shall be
used to calculate emissions of criteria pollutants and hazardous air pollutants per this permit
and be provided to the Division upon request.
ALTERNATIVE OPERATING SCENARIOS
47. AIRS Point 013: The control device may be replaced with a like-kind control device 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 control
device shall be the same make and model as authorized in this permit. All control device
replacements installed and operated as authorized by this permit must comply with all terms
and conditions of this construction permit. The owner or operator shall maintain a log on-site
or at a local field office to record the start and stop dates of any control device replacement,
the manufacturer, model number and serial number of the replacement control device.
48. AIRS Poi ,��. � it P • lions t-e (APE • - � lfic
manufac er, mo. a ':serial n ber o_• z74,,:•-placzodent control de - must be filed with
the DivisIT within e,,. cad e of cods g op r a repla T ment control
device u -r the A rn. e I. A ting •vis . The APEN m be accompanied by
the appr, pate ' fil ,: fee a c• -r lette pl ti ing that the o r or operator is
exercise r _il ativ= peratin• and h . r aced the contr.L•evice.
49. AIRS Point 013: Within one hundred and eighty days (180) of startup of the replacement control
device in accordance with the Alternate Operating Scenario provision, the owner or operator
must conduct an initial source compliance test to measure the mass emission rates of the
pollutants listed below, demonstrate compliance with the emissions limit in this permit, and to
demonstrate a minimum destruction efficiency of 98% for volatile organic compounds (VOC).
During the test, the owner or operator must measure:
• mass emission rates of VOC at the inlet of the control device (M1) using EPA or other
division approved methods;
• mass emission rates of VOC at the outlet of the control device (MO using EPA or other
division approved methods; and
• mass emission rates of NOx and CO at the outlet of the control device using EPA or
other division approved methods.
Additionally, the following parameters may be required to be measured during the test:
• combustion chamber temperature;
• gas flow rate;
• supplemental fuel flow rate;
• gas heat content; and
• gas composition.
The destruction efficiency (DE) for VOC must be calculated using the following equation:
Page 14 of 23
CDPHE COLORADO
CO . Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
DE (%) = 100*(M-Mo)/Mi
The test protocol, test, and test report must be in accordance with the requirements of the
Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to
the Division for review and approval at least thirty (30) days prior to testing. No compliance
test will be conducted without prior approval from the Division. Within thirty (30) days
following completion of the test(s), a compliance test report must be submitted to the
Division for review. Additional time may be granted upon written request. Any compliance
test conducted to demonstrate compliance with a monthly or annual emission limitation shall
have the results projected up to the monthly or annual averaging time by multiplying the test
results by the Process Limit(s) for that averaging time as indicated in the Process Limitations
and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3)
Records of the annual compliance tests must be maintained by the owner or operator for a
minimum of five (5) years and made available to the Division for inspection upon request.
Actual emissions calculations must be completed in accordance with PS Memo 20-02.
ADDITIONAL REQUIREMENTS
50. All prevlpf of t i "1a s re cant d upon rz i ,
51. A revise« ,it Pollu : t ission N , ce ( N . ust •filed: (Regulat' a Number 3, Part A,
II.C.) tea.
• A . ually byx •ril th wh er fit in e :ase in emission `sccurs as follows:
F 8 Feria 4 llutant:
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 15 of 23
CDPHE COLORADO
CO Air Pollution Control Division
- Department of Publ c 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.
52. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall
apply to this source at any such time that this source becomes major solely by virtue of a
relaxation in any permit condition. Any relaxation that increases the potential to emit above
the applicable Federal program threshold will require a full review of the source as though
construction had not yet commenced on the source. The source shall not exceed the Federal
program threshold until a permit is granted. (Regulation No. 3 Part D).
53. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and
Natural Gas Production Facilities major stationary source requirements shall apply to this
stationary source at any such time that this stationary source becomes major solely by virtue
of a relaxation in any permit limitation and shall be subject to all appropriate applicable
requirements of Subpart HH. (Reference: Regulation No. 8, Part E)
GENERAL TERMS AND CONDITIONS
54. 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. u•on a request for transfer of ownership and the
submltta' a -d A• A< equire
55. If this p it speci'-tIc.11 - lnalg :then the remainder
zatio' as been ranter
of this c• i ition is as. ;the '- ssua j ° 1 constr ion permit does not
provide al" auth e; t y p, this .L ivlty o 0 is source. Fin l: _authorization of the
permit = t be red, nom ordance with s provisions of 25-7-
114.5(12'l'77;7.- `. and • iD CC Regu'r Number •. B, Section III. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self-certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self-Certify for Final Authorization section of this permit.
56. 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.
57. 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.
58. 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
Page 16 of 23
CDP ( COLORADO
CO Air Pollution Control Division
Department of Public Health&Envfonment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
59. 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.
60. 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:
Bradley Eades
Permit Engineer
Permit ory
ZZ;Issu• e •n
Issuan 1 pri 013 '° . . -• ® Bonan Cr Energy Opera g LLC.
Issuane= .w 7 Apri '016 M•'• emission acrs and throughp limit for
Point 002 Truck Loadout.
Added Point 001 Condensate Tanks from GP01.
Canceled Point 003 Fugitives as emissions have fallen
below APEN thresholds.
Added Point 010 Produced Water Tanks, Point 011
Emergency Flare, Point 013 LP Separator Venting, and
Point 014 VRT Venting.
Issuance 3 23 September Added Point 016. No change to permit conditions for
2016 any other point.
Issuance 4 21 February Modified through-puts, emission factors, and
2017 emissions. Cancelled Points 011 and 014.
Issuance 5 26 June 2017 Remove Point 010 and add Point 017.
Issuance 6 July 16, 2019 Updated emission factor and throughput for Point
001. Reduced throughput from 289,080 bbl/yr and
requested VOC emissions from 45.7 tpy.
Removed Point 016 which was canceled 11/30/2017.
Page 17 of 23
CDPHE COLORADO
CO Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Issuance 7 This Issuance Issued to Bonanza Creek Energy Operating Company,
LLC
Modification to increase throughput for Point 001,
002, 013 due to addition of wells. Add Point 010 to
permit (previously exempt). Add VRT to Point 013.
Increase required control efficiency of Point 013.
Update emission factors based on site-specific
sampling.
t J.; 151* • • ,w t
151 dr
4)4
Page 18 of 23
,^ CDPHE COLORADO
CO ,% Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The follows :' -H - 7 of t P °3 report l� air po _ :4. �`� . used upon the
process limi 61.s indict d i his per This atio listed to info the operator of the
Division's an 2 sis oft sp w ' ' * ' unds if t r- • . -(s) ope e at the permitted
limitations
c trolled •ntrolled
AIRS Pollutant CAS K# Emissions Emissions
Point (lb/yr) (lb/yr)
Benzene 71432 1,295 65
Toluene 108883 1124 56
Ethylbenzene 100414 90 5
001 Xylenes 1330207 318 16
n-Hexane 110543 9821 491
2,2,4-
540841 26 1
Trimethylpentane
Benzene 71432 142 7
Toluene 108883 110 6
Ethylbenzene 100414 9 <1
002 Xylenes 1330207 36 2
n-Hexane 110543 1766 88
2,2,4-
540841 4 <1
Trimethylpentane
010 Benzene 71432 279 14
Page 19 of 23
4 CD P tiE COLORADO
CO Air Pollution Control Division
'" Department of Public Heatih.&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Toluene 108883 165 8
Ethylbenzene 100414 9 1
Xylenes 1330207 30 2
n-Hexane 110543 132 7
Benzene 71432 1656 33
Toluene 108883 1344 27
Ethylbenzene 100414 129 3
013 Xylenes 1330207 510 10
n-Hexane 110543 15036 301
2,2,4-
540841 9 <1
Trimethylpentane
Benzene 71432 10,642 495
Toluene 108883 15,489 736
. a.����-ne � X414 � �.�.. .
017
Xylene , 4207 ;: 1',17§4,-..- 772
n-Hexa o ' , 10543 E i•98 63
22 i - 01,
:3 5
T a fentan=a
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per
year(lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 001:
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
NOx 0.0021 0.0021 AP-42, Ch 13.5
CO 0.0096 0.0096 AP-42, Ch 13.5
VOC 1.2442 0.0622
71432 Benzene 0.0032 2E-4 ProMax and Site-
108883 Toluene 0.0027 1E-4 specific
pressurized
1330207 Xylene 0.0008 4E-5
liquid sample
110543 n-Hexane 0.0239 1E-3
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
Page 20 of 23
4 C�E COLORADO
CO � Air Pollution Control Division
ti Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Point 002:
Uncontrolled Controlled
Pollutant CAS # Emission Emission Source
Factors Factors
lb/bbl lb/bbl
N0x 3.3E-4 3.3E-4
CO 1.5E-3 1.5E-3 AP-42
Chapter
V0C 0.2195 0.0110 5.2
n-Hexane 110543 4.3E-3 2.2E-4
The uncontrolled V0C emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version
1/95) using the following values:
L = 12.46*S*P*M/T
_.... .. ,-1.:4.77rft,':
., , . pia
S = +. ! (Su• - .ed ding • ' Gated. ' al se )
P (t vapor p su 7 9 •
M (v or moles r .2 lbAT' m•
T (t�„ �peratur off li?yid loa--•) 5
The uncont • • n:- -crite . reportab •e pollutantC ) emission fact•,' were calculated by
multiplying the mass fraction of each NCRP in the vapors by the V0C emission factor. N0x and CO
emissions are calculated using factors from AP-42 Chapter 13.5 and the ideal gas law (379
scf/lbmol, MW of vapors 51.2 lb/lbmol) and heat content of tank working and breathing losses.
Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of
100%.
Point 010:
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
V0C Flash Liberation
0.0174 0.0009 Analysis of site-
specific
71432 Benzene pressurized
9.6E-4 4.8E-5 liquid sample
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
Page 21 of 23
A CDPHE COLORADO
CO 9 Air Pollution Control Division
Department of Public Heelth Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Point 013:
Uncontrolled Controlled
CAS # Pollutant Emission Emission Source
Factors Factors
(lb/MMscf) (lb/MMscf)
NOx 149.40 149.40 AP-42 Chapter
13.5 ft Site-
CO 681.07 681.07 Specific Gas
Analysis
VOC 73,127.46 1,462.55
71432 Benzene 137.87 2.76 Extended Gas
108883 Toluene 111.84 2.24 Analysis of LP gas
1330207 Xylene 42.44 0.85 and VRT gas
110543 n-Hexane 1,275.41 25.06
Note: Applicant is using weighted emission factors based on commingled LP separator and VRT
gas streams. Emission factors above reflect an assumed volumetric composition of 50% LP gas and
50%VRT 0 f. ;' A g sed on g7 Amin le 7 btu/scf. The
controlled fissions # or r this p t area on a trot efficiencytv 98%.
Actual co to olled e r ion ' alcul I u • th metho
M thl =:l E Visions = t ; VPLx E (100%— CE)] 1.4VpL, x EF]
where:
Vtotal = Total volume of gas from the emission source sent to
control device during the month (MMscf)
VPLx = Total volume of gas from the emission source sent to
control device while pilot light was not lit (MMscf)
EF = Uncontrolled emission factor for gas venting (lb/MMscf)
CE = 98%
Point 017:
The emission levels contained in this permit are based on information provided in the application
and the GRI GlyCalc 4.0 model. Controlled emissions are based on an enclosed combustor control
efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN must be submitted no later than 30 days before the five-year term expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
Page 22 of 23
Aek `DP COLORADO
CO Air Pollution Control Division
Department of Public Health B Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC, CO, NOx, HAPs
NANSR Synthetic Minor Source of: VOC, NOx
MACT HH Area Source Requirements: Applicable
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at they ° ted 1,7
http://ecfr oaccess v/
'.
•Part 60 ndardsPe rm• for
a urces
NSPS am. $F Sub� LL= a Subpar . .
NSPS Part 60, Appendixes Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA- Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 23 of 23
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Bradley Fades
Package t$: 421696
Received Date: 11/6/2019
Review Start Date: 3/9/2020
Section 01 - Facility Information
Company Name: Bonanza Creek Energy Operating Company LLC Quadrant Section Township Range
County AIRS ID: 123 SESW 34 5N 63
Plant AIRS ID: 9A82
Facility Name: North Platte 24-34 Production Facility
Physical
Address/Location: SESW quadrant of Section 34, Township SN, Range 63W
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 #
AIRs Point #
Emissions (Leave blank unless Issuance Self Cert
(Leave blank unless APCD Emissions Source Type Equipment Name Action Engineering Remarks
Control? APCD has already # Required?
has already assigned)
assigned)
EF decreasing from 17.5
to 1.2. Increase
Permit througput from 2 new
001 - Condensate Tank _ CNDTK-01 Yes 12WE3163 7 Modification wells
Update EF, increase
Permit throughput from 2 new
002 Liquid Loading L-01 Yes 12WE3163 7 Modification wells,
Point was prey. XA but
emissions will increase
with mod. New
Permit Initial emission factors using
010 Produced Water Tank PWT-01 Yes - 12WE3163 7 Issuance FLA
Increase throughput
Permit and request 98%
013 Separator Venting LPGFL Yes 12WE3163 7 Modification control
Dehydrator .
Section 03 - Description of Project
Applicant is requesting modification due to additional throughput from two (2) new wells. Applicant is requesting new synthetic mionr limits to limit PTE below 50 tpy VOC .
As of January 27, 2020, this facility became a Major Source for Purposes of NANSR and Title V (Regulation 3, Part D). Source will become synthetic minor upon issuance of
this permit. Summary of changes to each point above is included below:
Point 001: Revise emission factors based on new site-specific sampling. Increase throughput. Facilitiy uses two (2) vapor recovery towers for additional gas liquid
separation prior to the storage tanks. Previous emission models using ProMax did not take credit for additional gas capture at the VRT prior to the storage tanks. By adding
the VRTs into the ProMax simulation, the emission factor is reduced (on a lb/bbl basis). Previous applications requested flexibility for liquids to bypass the VRT, however,
that flexibility has been removed with this issuance and all liquids should be processed in the VRT at approximately 2 psig prior to storage in storage tanks.
Point 002: Update EF, increase throughput.
Point 010 was removed from the permit with Issuance 5 in 2017 due to emissions dropping below reporting thresholds. With this issuance, applicant i s requesting to add
point 010 to the facility wide permit based on increased throughput. Emission factors developed using flash liberation analysis of pressurized sample.
Point 013: Increase throughput, request limits based on 98% control at enclosed combustors. Include emissions from VRT. Commingled (LP sep and VRT) stream is sent to
combustor and permitted with Point 013.
Sections 04, OS & 06 - For Division Use Only
Section 04 - Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Requesting Synthetic Minor Permit
*New syn minor limits since source was designated as Major upon nonattainment reclassification to Serious in January 2020
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes, indicate programs and which pollutants: SO? NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) I III
IIITitle V Operating Permits (OP) ✓ ✓ ✓
Non-Attainment New Source Review (NANSR) ./ ✓
Is this stationary source a major source? No
If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) I
I I I l I I I I I I
Title V Operating Permits (OP)
Non-Attainment New Source Review (NANSR)
Condensate Storage Tank(s) Emissions Inventory
Section 01 - Administrative Information
Facility AIRS ID: 123 9A82 001
County Plant Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Eight (8) 800 barrel fixed roof condensate storage vessels connected via liquid line.
Description:
Emission Control Device Enclosed combustors (5-teed L30-0011 & 1-Cimarron 48" HV)
Description:
Requested Overall VOC & HAP Control Efficiency %: 95.0
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Condensate Throughput = 328,500.0 Barrels (bbl) per year
Requested Permit Limit Throughput = 410,625.0 Barrels (bbl) per year Requested Monthly Throughput = 34875.0 Barrels (bbl) per month
Potential to Emit (PTE) Condensate
Throughput = 410,625.0 Barrels (bbl) per year
Secondary Emissions - Combustion Device(s)
Heat content of waste gas = 2748.0 Btu/scf
Volume of waste gas emitted per BBL of
liquids produced = 11.2 scf/bbl
Actual heat content of waste gas routed to combustion device = 10,137.1 MMBTU per year
Requested heat content of waste gas routed to combustion device = 12,671.3 MMBTU per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device = 12,671.3 MMBTU per year
Control Device
Pilot Fuel Use Rate: 100.8 scfh 0.9 MMscf/yr
Pilot Fuel Gas Heating Value: 2748 Btu/scf 2426.5 MMBTU/yr
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions? Yes
Emission Factors Condensate Tank
Uncontrolled Controlled
Pollutant (lb/bbl) (lb/bbl) Emission Factor Source
(Condensate (Condensate
Throughput) Throughput)
VOC 1.2442 0.0622 Site Specific E.F. (includes flash)
Benzene 3.2E-03 2E-04 Site Specific E.F. (includes flash)
Toluene 2.7E-03 1E-04 Site Specific E.F. (includes flash)
Ethylbenzene 2.2E-04 1E-05 Site Specific E.F. (includes flash)
Xylene 7.7E-04 4E-05 Site Specific E.F. (includes flash)
n-Hexane 2.4E-02 1E-03 Site Specific E.F. (includes flash)
224 TMP 6.2E-05 3E-06 Site Specific E.F. (includes flash)
Control Device
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) (Ib/bbl) Emission Factor Source
(waste heat (Condensate
combusted) Throughput)
PM10 0.0075 0.0002 AP-42 Table 1.4-2 (PM10/PM.2.5)
PM2.5 0.0075 0.0002 AP-42 Table 1.4-2 (PM10/PM.2.5)
NOx 0.0680 0.0021 AP-42 Chapter 13.5 Industrial Flares (NOx)
CO 0.3100 0.0096 AP-42 Chapter 13.5 Industrial Flares (CO)
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) (lb/MMscf) Emission Factor Source
(Waste Heat (Pilot Gas
Combusted) Throughput)
PM10 0.0075 20.4753 AP-42 Table 1.4-2 (PM10/PM.2.5)
PM2.5 0.0075 20.4753 i AP-42 Table 1.4-2 (PM10/PM.2.5)
NOx 0.0680 186.8640 AP-42 Chapter 115 Industrial Flares (NOx)
CO 0.3100 851.8800 AP-42 Chapter 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)
VOC 255.5 204.4 10.2 255.46 12.77 2169.6
PM10 0.1 0.0 0.0 0.06 0.06 9.6
PM2.5 0.1 0.0 0.0 0.06 0.06 9.6
NOx 0.5 0.4 0.4 0.51 0.51 87.2
CO 2.3 1.9 1.9 2.34 2.34 397.5
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year)
Benzene 1295.1 1036.1 51.8 1295.1 64.8
Toluene 1123.8 899.0 45.0 1123.8 56.2
Ethylbenzene 89.9 71.9 3.6 89.9 4.5
Xylene 317.5 254.0 12.7 317.5 15.9
n-Hexane 9820.8 7856.7 392.8 - 9820.8 491.0
224 TMP 25.6 20.5 1.0 25.6 1.3
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Condensate Storage Tank(s ) Emissions Inventory
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B Source requires a permit
Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XII.C-F
Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G
Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb
Regulation 6, Part A, NSPS Subpart OOOO Storage tank is not subject to NSPS OOOO.
NSPS Subpart 0000a Storage Tank is not subject to NSPS 0000a
Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company use the state default emissions factors to estimate emissions? No
If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company use a site specific emissions factor to estimate emissions? .
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the
facility being permitted? This sample should be considered representative which generally means site-specific and
collected within one year of the application received date. However, if the facility has not been modified (e.g., no
new wells brought on-line), then it may be appropriate to use an older site-specific sample. Yes
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08 - Technical Analysis Notes
Applicant indicates that new wells are not adjacent for purposes of source aggregation since they are located greater than 1/4 mile from this facility. Source also indicates that there are no separators
located at the remote well pads and as such has made an argument that no processing takes place per the definition contained in NSPS Kb ("processing" as included in exemption for sources < 10K bbl
capacity located prior to custody transfer). The Division agrees with this interpretation that liquids at the remote wellheads are not not "processed" prior to being transferred via pipeline to this faciltiy. As
a result, this source qualifies for the exemption from NSPS Kb for vessels with "design capacity less than or equal to 1,589874 m3 [ 10,000 BBL] used for petroleum1 or condensate stored, processed, or
treated prior to custody transfer" as defined in 60.111b.
The regulatory analysis section supplied in this analysis contains references to Regulation 7 prior to December 2019 revisions. The correct regulation citations have been included in the permit. Based on
date storage tank was constructed (prior to May 1, 2020) it is not subject to requirements in Regulation 7, Part D,Section II.C.4.a. (i) or (ii).
Section 09 - Inventory SCC Coding and Emissions Factors
Uncontrolled
Emissions
AIRS Point # Process ti SCC Code Pollutant Factor Control % Units
01 4-04-003-11 Fixed Roof Tank, Condensate, working+breathing+flashing losses PM10 0.01 0 lb/1,000 gallons condensate throughput
PM2.5 0.01 0 lb/1,000 gallons condensate throughput
NOx 0.06 0 lb/1,000 gallons condensate throughput
VOC 29.6 95 lb/1,000 gallons condensate throughput
CO 0.27 0 lb/1,000 gallons condensate throughput
Benzene 0.08 95 lb/1,000 gallons condensate throughput
Toluene 0.07 95 lb/1,000 gallons condensate throughput
Ethylbenzene 0.01 95 lb/1,000 gallons condensate throughput
Xylene 0.02 95 lb/1,000 gallons condensate throughput
n-Hexane 0.57 95 lb/1,000 gallons condensate throughput
224 TMP 0.00 95 lb/1,000 gallons condensate throughput
3 of 17 C:\Users\beades\Desktop\Remote Work\My Packages\Package 421696 (Bonanza 24-34)\12WE3163.CP7
Condensate Tank Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and B-APEN and Permit Requirem_ents
'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.0.1.a)?
2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3. Part B, Section II.D.3)?
You have indicated that source is in the Non-Attainment Area
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? Yes Source Requires an APEN. Go to
2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? No Go to next question
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than S TPY or CO emissions greater than 10 TPY (Regulation 3, Part 8, Section 11.0.2)? Yes Source Requires a permit
Source requires a permit
Colorado Regulation 7, Section XII.C-F
1. Is this storage tank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area? Yes Continue - You have indicated th
2. Is this storage tank located at an oil and gas exploration and production operation, natural gas compressor station or natural gas drip station? Yes Continue - You have indicated th
3. Is this storage tank located upstream of a natural gas processing plant? Yes Source is subject
Storage tank is subject to Regulation 7, Section XII.C•F
Section XII.C.1 -General Requirements for Air Pollution Control Equipment - Prevention of Leakage
Section XII.C.2 - Emission Estimation Procedures
Section XII.D - Emissions Control Requirements
Section XII.E - Monitoring
Section XII.F - Recordkeeping and Reporting
Colorado Regulation 7, Section XII.G
1. Is this storage tank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area? Yes Continue - You have determined
2. Is this storage tank located at a natural gas processing plant? No Storage Tank is not subject to Re
3. Does this storage tank exhibit "Flash" (e.g. storing non-stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC?
Storage Tank is not subject tc Regulation 7, Section XII.G
Section XII.G.2 - Emissions Control Requirements
Section XII.C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage
Section XII.C.2 - Emission Estimation Procedures
Colorado Regulation 7,Section XVII
1. Is this tank located at a transmission/storage facility? Nc Continue - You have indicated th
2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station'or natural gas processing plant? Yet Go to the next question - You ha
3. Is this condensate storage tank a fixed roof storage tank? Yes Go to the next question
4. Are uncontrolled actual emissions`of this storage tank equal to or greater than 6 tons per year VOC? Yes Source is subject to parts of Reg'
Storage tank is subject to Regulation 7, Section XVII. I . C.1 & C.3
Section XVII.B- General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.C.1 - Emissions Control and Monitoring Provisions
Section XVII.C.3 - Recordkeeping Requirements
5. Does the condensate storage tank contain only "stabilized" liquids? No Source is subject to all provision:
Storage tank is subject to Regulation 7, Section XVII.C.2
Section XVII.C.2- Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
40 CFR, Part 60, Subpart Kb,Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m3) (-472 BBLs]? Yes Go to the next question
2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? Yes Storage Tank is not subject NSPS
a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 (^'10,000 BBLJ used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.111b?
3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984?
4. Does the tank meet the definition of "storage vessel"3 in 60.11lb?
5. Does the storage vessel store a "volatile organic liquid (VOL)"sas defined in 60.11lb?
6. Does the storage vessel meet any one of the following additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa ("29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or
b. The design capacity is greater than or equal to 151 m3 ("950 BBL] and stores a liquid with a maximum true vapor pressure° less than 3.5 kPa (60.11ob(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 pressure6 less than 15.0 kPa(60.110b(b))?
7. Does the storage tank meet either one of the following exemptions from control requirements:
a. The design capacity is greater than or equal to 151 m3 (-950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa?; or
b. The design capacity is greater than or equal to 75 M3 (-472 BBL) but less than 151 m3 (-950 Ball and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa but less than 27.6 kPa?
Storage Tank is not subject to NSPS Kb
40 CFR, Part 60, Subpart 0000/0000a, Standards of Performance for Crude Oil and Natural Gas Production,Transmission and Distribution
1. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? Yes Continue - You have indicated th
2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? too Storage Tank is not subject NSPS
3. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after September 18, 2015? Yes Go to the next question
4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? No Storage Tank is not subject NSPS
5. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430/60.5430a?
6. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH?
Storage Tank is not subject to NSPS 0000a
[Note: If a storage vessel is previously determined to be subject to NSPS 0000/0000a due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000/0000a per
60.5365(e)(2)/60.536Sa(e)(2) even if potential VOC emissions drop below 6 tons per year)
40 CFR. Part 63, Subpart MACT HH, Oil and Gas Production Facilities
1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: fie • Continue - You have indicated th
a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR
b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.760(a)(3))?
2. Is the tank located at a facility that is major' for HAPs? No Storage Tank is not subject MAC
3. Does the tank meet the definition of "storage vessel"` in 63.761?
4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"5 per 63.761?
5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000?
Storage l ank is not iubject to MACI HH
Subpart A, General provisions per §63.764 (a) Table 2
§63.766 - Emissions Control Standards
§63.773 - Monitoring
§63.774 - Recordkeeping
§63.775 - Reporting
RACT Review
RACT review is required if Regulation 7 does not apply AND if the tank is in the non-attainment area. If the tank meets both criteria, then review RACT requirements.
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing
regulations. and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non-mandatory language such as "recommend,""may," "should."and "can,"is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must'and "required'are intended to descnbe controlling requirements under the terms of the Clean Air
Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself
Hydrocarbon Loadout Emissions Inventory
Section 01 - Administrative Information
123 9A82 002
Facility AIRs ID:
County Plant Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Loadout of condensate to tank trucks using submerged fill.
Description:
Emission Control Device Enclosed combustors (5-Leed L30-0011 & 1-Cimarron 48" HV)
Description:
Is this loadout controlled? Yes
Requested Overall VOC & HAP Control Efficiency %: 95
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Hydrocarbon Loadout
Actual Volume Loaded = 410,625 Barrels (bbl) per year
Requested Permit Limit Throughput = 410,625 Barrels (bbl) per year Requested Monthly Throughput = 34875 Barrels (bbl) per month
Potential to Emit (PTE) Volume Loaded = 410,625 Barrels (bbl) per year
Secondary Emissions - Combustion Device(s)
Heat content of waste gas = 29% Btu/scf
Actual Volume of waste gas emitted per year = 667076 scf/year
Requested Volume of waste gas emitted per year = 667076 scf/year
Actual heat content of waste gas routed to combustion device = 1,972 MMBTU per year
Requested heat content of waste gas routed to combustion device = 1,972 MMBTU per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device = 1,972 MMBTU per year
Control Device
Pilot Fuel Use Rate: 0 scfh 0.0 MMscf/yr Pilot emissions are accounted for with condensate storage tanks (Point 001).
Pilot Fuel Gas Heating Value: Btu/scf 0.0 MMBTU/yr
Section 04 - Emissions Factors & Methodologies
Does the company use the state default emissions factors to estimate emissions? No `Y
Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility
being permitted? Yes r4 The stabilized hydrocarbon liquid sample is valid for developing site specific emissions factors.
Loading Loss Equation
L = 12.46`S`P;M/T
Factor Meaning Value Units Source
S Saturation Factor 0.6 AAP-42 Chapter 5.2 Table 5.2-1 Submerged Loading: Dedicated Normal Service (S=0.6)
P True Vapor Pressure 7.91 psia Calculated using Mpbpwinv1.43 (for species properties) assuming Raoult's Law.
M Molecular Weight of Vapors 51.2 Ib/Ib-mol Chapter 7, Equation 1-23
T Liquid Temperature 524 Rankine
L Loading Losses 5.778091969 lb/1000 gallons
0.242679863 lb/bbl
Component Mass Fraction Emission Factor Units Source
VOC 0.90433 0.21946268 lb/bbl Equation 1-22 Chapter 7 (AP-42)
Benzene 0.001424981 0.000345814 lb/bbl Equation 1-22 Chapter 7 (AP-42)
Toluene 0.001103859 0.000267884 lb/bbl Equation 1-22 Chapter 7 (AP-42)
Ethylbenzene 0.000094 2.28119E-05 lb/bbl Equation 1-22 Chapter 7 (AP-42)
Xylene 0.000366 8.88208E-05 lb/bbl Equation 1-22 Chapter 7 (AP-42)
n-Hexane 0.017721953 0.004300761 lb/bbl Equation 1-22 Chapter 7 (AP-42)
224 TMP 0.000042 1.01926E-05 lb/bbl Equation 1-22 Chapter 7 (AP-42)
Emission Factors Hydrocarbon Loadout
Uncontrolled Controlled
Pollutant (lb/bbl) (lb/bbl) Emission Factor Source
(Volume
(Volume Loaded) Loaded)
VOC 0.2195 0.0110 Site Specific - AP-42: Chapter 5.2, Equation 1 0.242679863 0.0121
Benzene 3.5E-04 1.7E-05 Site Specific - AP-42: Chapter 5.2, Equation 1
Toluene 2..7E-04 1.3E-05 Site Specific - AP-42: Chapter 5.2, Equation 1
Ethylbenzene 2.3E-05 1.1E-06 Site Specific - AP-42: Chapter 5.2, Equation 1
Xylene 8.9E-05 4.4E-06 Site Specific - AP-42: Chapter 5.2, Equation 1
n-Hexane 4.3E-03 2.2E-04 Site Specific - AP-42: Chapter 5.2, Equation 1
224 TMP 1.0E-05 5.1E-07 Site Specific - AP-42: Chapter 5.2, Equation 1
Control Device
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source
(Volume
(waste heat combusted) Loaded)
PM10 0.0075 3.58E-05 AP-42 Table 1.4-2 (PM1O/PM.2.5)
PM2.5 0.0075 3.58E-05 AP-42 Table 1.4-2 (PM10/PM.2.5)
SOx 0.0006 2.82E-06 AP-42 Table 1.4-2 (SOx)
NOx 0.0680 3.27E-04 AP-42 Chapter 13.5 Industrial Flares (NOx)
CO 0.3100 1.49E-03 AP-42 Chapter 13.5 Industrial Flares (CO)
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) (lb/MMscf) Emission Factor Source
(Pilot Gas
(Waste Heat Combusted) Throughput)
PM10 0.0000
PM2.5 0.00013 `,,"
c l
SOx 0.0000 . 4 w` ' ;'4-7 '
NOx 0.0000
CO 0.0000
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Hydrocarbon Loadout Emissions Inventory
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 0.01 0.01 0.01 0.01 0.01 1
PM2.5 0.01 0.01 0.01 0.01 0.01 1 _
SOx 0.00 0.00 0.00 0.00 0.00 0
NOx 0.07 0.07 0.07 0.07 0.07 11
VOC 45.06 45.06 2.25 45.06 2.25 383 49.82520931 2.491260466
CO 0.31 0.31 0.31 0.31 0.31 52
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year)
Benzene 142 142 7 142 7
Toluene 110 110 6 110 6
Ethylbenzene 9 9 0 9 0
Xylene 36 36 2 36 2
n-Hexane 1766 1766 88 1766 8.8
224 IMP 4 4 0 4 0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B Source requires a permit
Regulation 7 Part D Section II.C.5. The hydrocarbon liquids loadout source is subject to Regulation 7 Part D Section II.C.5.
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Section 08 - Technical Analysis Notes
Applicant is assuming loadout vapors have a composition of 90.4% wt VOC. This, and wt % HAPs, are based on the sampled sales oil composition (sampled 9/5/19) and equation 1-23 in chapter 7 of AP-42.Generally, applicants will assume VOC composition of
100% for loadout vapors, however, since the composition in this case is based on site-specific sample data, and the loading loss equation is intended to calculate the total mass of vapors, I will approve the methodology proposed here.
Section 09 - Inventory SCC Coding and Emissions Factors
Uncontrolled
Emissions
AIRS Point # Process # SCC Code Pollutant Factor Control % Units
002 01 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) PM10 0.00 0 lb/1,000 gallons transferred
PM2.5 0.00 0 lb/1,000 gallons transferred
SOx 0.00 0 lb/1,000 gallons transferred
NOx 0.01 0 lb/1,000 gallons transferred
VOC 5.2 95 lb/1,000 gallons transferred
CO 0.04 0 lb/1,000 gallons transferred
Benzene 0.01 95 lb/1,000 gallons transferred
Toluene 0.01 95 lb/1,000 gallons transferred
Ethylbenzene 0.00 95 lb/1,000 gallons transferred
Xylene 0.00 95 lb/1,000 gallons transferred
n-Hexane 0.10 95 lb/1,000 gallons transferred
224 TMP 0.00 95 lb/1,000 gallons transferred
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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
5 site is in the Non•Attainirertt Acea
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)? C`%
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 II.D.3)? ;
You have inaicated 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)? Yes Go to next question.
2. Is the loadout located at an exploration and production site(e.g., well pad)(Regulation 3, Part B. Section II.D.1.1)? Yes Go to the next question
3. Is the loadout operation loading less than 10,000 gallons(238 BBLs)of crude oil per day on an annual average basis? No Go to next question
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? No Go to next question
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? No Go to next question
6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY. NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Yes The loadout requires a permit
Source rdcu'rc•s a permit
Colorado Regulation 7 Part D Section II-C.S.
1. Is this condensate storage tank hydrocarbon liquids loadout located at a well production facility, natural gas compressor station or natural gas processing plant? Yes Go to next question.
2. Does the facility have a throughput of hydrocarbon liquids loadout to transport vehicles greater than or equal to 5,000 barrels? res Source is subject to Regulation 7 Part D Section Il.C.5.
The hydroc:rben liquids Loadout source is subject to Re,Tulatton 7 Part D section L C.5
Section II.C.S.a.(i)-Compliance Schedule
Section II.C.5.a.(ii)-Operation without Venting
Section II.C.5.a.(iii)- Loadout Equipment Operation and Maintenance
Section II.C.S.a.(iv)- Loadout observations and Operator Training
Section II.C.5.a.(v) •Records
Section II.C.5.a.(vi) - Requirements for Air Pollution Control Equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a
rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or
any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations,
and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non-mandatory language such as 'recommend," "may,""should,"and 'can,"is intended to
describe APCD interpretations and recommendations. Mandatory terminology such as "must"and "required"are intended to descnbe controlling requirements under the terms of the Clean Air Act and Air
Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself
Storage Tank(s) Emissions Inventory
Section 01 - Administrative Information
123 9A82 010
Facility AIRs ID:
County Plant Point
Section 02 - Equipment Description Details
Storage Tank Liquid
n t
Detailed Emissions Unit Two (2) 800 barrel produced water storage vessels connected via liquid line.
Description:
Emission Control Device Enclosed combustors (5-Leed L30-0011 & 1-Cimarron 48" NV)
Description:
Requested Overall VOC & HAP Control Efficiency %: 95.0
Limited Process Parameter f.equa0 T'Itroughput:;
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Throughput = 233,600.0 Barrels (bbl) per year
Requested Permit Limit Throughput = 292,000.0 Barrels (bbl) per year Requested Monthly Throughput = 24800.0 Barrels (bbl) per month
Potential to Emit (PTE) Condensate Throughput = 292,000.0 Barrels (bbl) per year
Secondary Emissions - Combustion Device(s)
Heat content of waste gas = 970.7 Btu/scf
Volume of waste gas emitted per BBL of liquids
produced = 0.8 scf/bbl
Actual heat content of waste gas routed to combustion device = 171.2 MMBTU per year
Requested heat content of waste gas routed to combustion device = 214.0 MMBTU per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device = 214.0 MMBTU per year
Control Device
Pilot Fuel Use Rate: 0 scfh 0.0 MMscf/yr Pilot fuel is accounted for with Point 001
Pilot Fuel Gas Heating Value: 0 Btu/scf 0.0 MMBTU/yr
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions? Yes
Emission Factors Produced Water Tank
Uncontrolled Controlled MW of Flash Gas
Pollutant (lb/bbl) (lb/bbl) Emission Factor Source 33.7669 Ib/Ibmol
(Produced Water (Produced Water
Throughput) Throughput) Wt % Flash Gas
VOC 0.0174 0.0009 Site Specific E.F. (includes flash) 25.8771
Benzene 9.6E-04 4.8E-05 Site Specific E.F. (includes flash) 1.424
Toluene 5.7E-04 2.8E-05 Site Specific E.F. (includes flash) 0.8436
Ethylbenzene 3.2E-05 1.6E-06 Site Specific E.F. (includes flash) 0.0471
Xylene 1.0E-04 5.1E-06 Site Specific E.F. (includes flash) 0.1511
n-Hexane 4.5E-04 2.3E-05 Site Specific E.F. (includes flash) 0.6719
224 TMP 0.0E+00 0.0E+00 Site Specific E.F. (includes flash) 0
Control Device
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source
(waste heat (Produced Water
combusted) Throughput)
PM10 0.00745 0.0000 AP-42 Table 1.4-2 (PM10/PM.2.5)
PM2.5 0.00745 0.0000 AP-42 Table 1.4-2 (PM10/PM.2.5)
SOx 0.0000
NOx 0.0680 0.0000 AP-42 Chapter 13.5 Industrial Flares (CO)
CO 0.3100 0.0002 AP-42 Chapter 13.5:Industrial Flares (NOx)
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (Ib/MM8tu) (Ib/MMscf) Emission Factor Source
(Pilot Gas Heat (Pilot Gas
Combusted) Throughput)
PM10 0.0-000
PM2.5 0.0000
SOx 0.0000
NOx 0.0000
VOC 0.0000
CO 0.0000
I
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 0.0 0.0 0.0 0.0 0.0 0.1
PM2.5 0.0 0.0 0.0 0.0 0.0 0.1
SOx 0.0 0.0 0.0 0.0 0.0 0.0
NOx 0.0 0.0 0.0 0.01 0.01 1.2
VOC 2.5 2.0 0.1 2.54 0.13 21.6
CO 0.0 0.0 0.0 0.03 0.03 5.6
8 of 17 C:\Users\beades\Desktop\Remote Work\My Packages\Package 421696 (Bonanza 24-34)\12WE3163.CP7
Storage Tank( s) Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year)
Benzene 279.3 223.4 11.2 279.3 14.0
Toluene 165.4 132.4 6.6 165.4 8.3
Ethylbenzene 9.2 7.4 0.4 9.2 0.5
Xylene 29-6 23.7 1.2 29.6 1.5
n-Hexane 131.8 105.4 5.3 131.8 6.6
224 TMP 0.0 _ 0.0 0.0 0.0 0.0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B Source requires a permit
Regulation 7, Part D,Section I.C, D, E, F Storage tank is subject to Regulation 7, Part D, Section I.C-F
Regulation 7, Part D,Section I.G, C Storage Tank is not subject to Regulation 7, Section I.G
Regulation 7, Part D,Section II.B, C.1, C.3 Storage tank is subject to Regulation 7, Part D, Section II, B, C.1 & C.3
Regulation 7, Part D,Section II.C.2 Storage tank is subject to Regulation 7, Part D, Section II.C.2
Regulation 7, Part D,Section II.C.4.a.(i) Storage Tank is not subject to Regulation 7, Part D, Section II.C.4.a(i)
Regulation 7, Part D,Section II.C.4.a.(ii) Storage Tank is not subject to Regulation 7, Part O, Section !I.C.4.a(ii), b - f
Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb
Regulation 6, Part A, NSPS Subpart OOOO Storage Tank is not subject to NSPS OOOO
NSPS Subpart OOOOa Storage tank is not subject to NSPS OOOOa.
Regulation 8, Part E, MACT Subpart HH Produced Water Storage tank is not subject to MACT HH
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
For condensate or crude oil tanks, does the company use the state default emissions factors to
estimate emissions?
If yes, are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the
uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than or equal to 80 tpy?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being
permitted (for produced water tanks, a pressurize liquid sample must be analyzed using flash liberation analysis)? This sample
should be considered representative which generally means site-specific and collected within one year of the application received
date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an
older site-specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Section 08 - Technical Analysis Notes
Applicant calculated site-specific emission factor based on flash alone (FLA). I had applicant provide a calculation of working and breathing losses which were demonstrated to be insignificant (emissions changed by <
0.1 tpy) and as such the approximation using flash only is being accepted as representative.
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.................. .., ._ ««_,.]...: .,...........,....z—ri r^,.. .._ _..... .._...... .,.....-...._..................n.].n........::.....r:......:n,.ux i ., ..;_...",.._ -_.... . - t-ya .....s_:-:11�
mcontrol vl :fill i r t r.....a sf F$ ].;:$3 ^.: ^=.. :....: _ -:- ' ?3• : : o w [ n f p u ;ic^
Pilot emissions are reported with Point 001 (common device). ..... � .....:.................^..._i.:_f..........,nn�. _ � __... �.. -..... .....__ . ...:_...._ ... . _ . ... ._. .... .�., _ . �=--- 1 ' _ �...., .i ,.��,..,.:. .�.,.,:::f�:aW:::�; F€�•�`F�:�...�;:.
( < ..:..:\i... n.��.....n..-.-.n...n..n..v............................-�.� tt•a,FCt ai. L.. ..,...... 4..-.... ....... J.._n "'ii. wrv�.-r A..r....w,w.v..v, ..,,�-.
....... S .-... .-.-._.. .^--... vY s...,,. i 3 3 c tf ...i:. :._.._.. ::. f{:[:..:f.: yc:_/ . —,:.:r_:._
........7f .. .e..-re:... _.._ _ Y- .. x s :. ;y::�.a:.-...-....; ' -. ... '.FFir nai:ij 1.:..r,:;c: d 3 ,a 3 R'. — e^�„..�;�= :(ae'.a;.;.:
r: :r .. .. .. .-L.i..0 II i f. iCi ..:E:_t. � .. s}1..3..<as•:...(: ,..:.....a.,..... _ —_ � -.........r,"'.w...,,W.„ aw.nw'w.v...a•`1.w�'��F ±�'-••..fi.,
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Section 09 - 5CC Coding and Emissions Factors (For Inventory Use Only)
Uncontrolled
Emissions
AIRS Point # Process # SCC Code Pollutant Factor Control % Units
;` 10 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses • PM10 0.00 0 lb/1,000 gallons Produced Water throughput
PM2.5 0.00 0 lb/1,000 gallons Produced Water throughput
SOx #REF! 0 lb/1,000 gallons Produced Water throughput
NOx 0.00 0 lb/1,000 gallons Produced Water throughput
VOC 0.41 95 lb/1,000 gallons Produced Water throughput
CO 0.01 0 lb/1,000 gallons Produced Water throughput
Benzene 0.02 95 lb/1,000 gallons Produced Water throughput
Toluene 0.01 95 lb/1,000 gallons Produced Water throughput
Ethylbenzene 0.00 95 lb/1,000 gallons Produced Water throughput
Xylene 0.00 95 lb/1,000 gallons Produced Water throughput
n-Hexane 0.01 95 Ib/1,000 gallons Produced Water throughput
224 TMP 0.00 95 lb/1,000 gallons Produced Water throughput
9 of 17 C:\Users\beades\Desktop\Remote Work\My Packages\Package 421696 (Bonanza 24-34)\12WE3163.CP7
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado R ulation 3 Parts A and B-APEN and Permit Re uirements
Source is in the Non-Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Produced Water Tanks have no grandfathering provisions
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
You have indicated that source is in the Non-Attainment Area
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A,Section IIA.1.a)? Yes'""' Source Requires an APEN. Go to
2. Produced Water Tanks have no grandfathering provisions No , Go to next question
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)? Yes. Source Requires a permit
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)? Yes Continue -You have indicated th
2. Is this storage tank located at oil and gas operations that collect,store,or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processing plant (Regulation 7, Part D, Section I.A.1)? Yes ' Continue -You have indicated th
3. Is this storage tank located at a natural gas processing plant (Regulation 7, Part D, Section 1.6)1 No Storage Tank is not subject to Re
4. Does this storage tank contain condensate? No
5. Does this storage tank exhibit"Flash" (e.g. storing non-stabilized liquids) emissions(Regulation 7, part D, Section I.G.2)? Yes
6. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year VOC (Regulation 7, Part D, Section 1.0.3.a(ii))? Yes
Storage tank is subject to Regulation 7, Part D, 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
Part D,Section I.E—Monitoring
Part D,Section I.F— Recordkeeping and Reporting
Storage Tank is not subject to Regulation 7, Section 1.6
Part D,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 l,Part D,Section II
1. Is this storage tank located at a transmission/storage facility? No Continue -You have indicated th
2. Is this storage tank' located at an oil and gas exploration and production operation , well production facility, natural gas compressor station3or natural gas processing plant`(Regulation 7, Part D, Section II.C)? Yes Go to the next question -You ha
3. Does this storage tank have a fixed roof(Regulation 7, Part 0,Section II.A.20)? Yes Go to the next question
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)? Yes Source is subject to parts of Reg'
Storage tank is subject to Regulation 7,Part D,Section II, 8,C.1 & C.3
Part D, Section 11.8—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
S. Does the storage tank contain only "stabilized" liquids (Regulation 7. Part D, Section II.C.2.b)? No. • Source is subject to all provision:
Storage tank is subject to Regulation 7, Part D. Section Il.C.2
Part D,Section II.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
Is the controlled storage tank located at a well production facility, natural gas compressor station, or natural gas processing plant constructed on or after May 1, 2020 or located at a facility that was modified on or after May 1, 2020, such
6. that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water(Regulation 7, Part 0, Section II.C 4.a.(i)? No ` Storage Tank is not subject to Re
Storage Tank is not subject to Regulation 7, Part 0, Section II.C.4.a{i)
Is the controlled storage tank located at a well production facility, natural gas compressor station, or natural gas processing plant constructed on or after January 1, 2021 or located at a facility that was modified on or after January 1,
7. 2021, such that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water (Regulation 7, Part D, Section II.C.4.a.(ii)? NO
Storage Tank is not subject to Regulation 7, Part D, Section ILC.4,a(ii), b - f
40 CFR, Part 60,Subpart Kb.Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m3) (-472 BBIs] (40 CFR 60.110b(a))? Yes Go to the next question
2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? Yes Storage Tank is not subject NSPS
a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 ["10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer as defined in 60.111b?
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 vesseln3 in 60.111b?
5. Does the storage vessel store a "volatile organic liquid (VOL)"sas defined in 60.111b?
6. Does the storage vessel meet any one of the following additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa ["29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or
b. The design capacity is greater than or equal to 151 m3 ["550 BBL] and stores a liquid with a maximum true vapor pressure'less than 3.5 kPa (60.110b(b))?; or
c. The design capacity is greater than or equal to 75 M3 ["472 BBL] but less than 151 m3 ["950 BBL] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110b(b))?
7. Does the storage tank meet either one of the following exemptions from control requirements:
a. The design capacity is greater than or equal to 151 m3 ["550 8B1] and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa?; or
b. The design capacity is greater than or equal to 75 M3 ["'472 BBL] but less than 151 m3 ["'950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa but less than 27.6 kPa?
Storage Tank is not subject to NSPS Kb
40 CFR. Part 60,Subpart 0000/0OOOa,Standards of Performance for Crude Oil and Natural Gas Production,Transmission and Distribution
1. Is this storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? Yes Continue -You have indicated th
2. Was this storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? Yes Go to the question 4.
3. Was this storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after September 18, 2015? No Storage Tank is not subject NSPS
4. Are potential VOC emissions` from the individual storage vessel greater than or equal to 6 tons per year? NO Storage Tank is not subject NSPS
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 0000
[Note: If a storage vessel is previously determined to be subject to NSPS 0000/OOOOa due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000/OOOOa per
60.5365(e)(2)/60.5365a(e)(2) even if potential VOC emissions drop below 6 tons per year]
40 CFR, Part 63, Subpart MACT HH,Oil and Gas Production Facilities
1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: Yes Continue -You have indicated th
a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR
b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user2 (63.760(a)(3))?
2. Is the tank located at a facility that is major3 for HAPs? : Storage Tank is not subject MAC
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 0000?
Produced Water 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
RACY 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.
Separator Venting Emissions Inventory
Section 01 - Administrative Information
123 9A82 013
Facility AIRS ID:
County Plant Point
Section 02 - Equipment Description Details
Venting of gas from eight (8) low pressure (LP) separators and two (2) vapor recovery towers (VRTs).
Detailed Emissions Unit Description:
Enclosed Combustors (1-GCO Beast 3200)
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %: 98
•
Limited Process Parameter Natural Gas Vented
Gas meter Yes, meter'rt currently inst ewan pera ona
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 = 1 .t? 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: 2197.0 Btu/scf (weighted based on decription in section 04)
Volume of waste gas emitted per BBL of ItI1IIIIIIi!
scf/bbl
Control Device 382.1511456 MMBtu/yr pilot
Pilot Fuel Use Rate: 16.80 scfh 0.1 MMscf/yr 0.012993139 tpy Nox
Pilot Fuel Gas Heating Value: 2596.7 Btu/scf 0.059233428 tpy CO
%/� ,�'����i�,_� *1821 scfh is based on app indication of 0.04 MMBtu/hr
Section 04 - Emissions Factors & Methodologies
Description
Gas comosition is based on a site-specific gas analysis from the VRT (sampled 9/5/19 @ 5psig) and a site-specific gas analysis from the LP separator (sampled 9/5119 @ 49 psig). The applicant will be required to conduct semi-annual
sampling of the commingled VRT/LP gas stream in order to demonstrate compliance with the emission factors used in the application. The respective LP and VRT sampled compositions are reflected below and the emission factors in
the subsequent table reflects a weighted average assuming 50/50 (LP/VRT) split of the gas comosition in the commingled stream.
VRT LP
MW 47.0 Ib/Ib-mol Displacement Equation MW 31.7 Ib/Ib-rnol #NAME?
Ex = O * MW * Xx / C
Weight % Weight %
O2/Argon 0.8 Argon/O2 0.0
CO2 0.8 CO2 3.8
N2 2.8 N2 0.1
methane 1.4 methane 19.7
ethane 11.0 ethane 25.0
propane 34.5 propane 28.7
isobutane 7.4 isobutane 4.1
n-butane 21.7 n-butane 10.5
isopentane 5.4 isopentane 2.2
n-pentane 6.5 n-pentane 2.6
cyclopentane 0.4 cyclopentane 0.2
n-Hexane 1.6 n-Hexane 0.6
cyclohexane 0.4 cyclohexane 0.2
Other hexanes 2.6 Other hexanes 1.0
heptanes 1.0 heptanes 0.4
methylcyclohexane 0.4 methylcyclohe>4 0.2
224-TMP 0.0 224-TMP 0.0
Benzene 0.2 Benzene 0.1
Toluene 0.1 Toluene 0.1
Ethylbenzene 0.0 Ethylbenzene 0.0
Xylenes 0.0 Xylenes 0.0
C8+ Heavies 1.1 C8+ Heavies 0.5
Total 100.0 Total 100.0
VOC Wt % 833 VOC Wt % 51 4
11 of 17 C:\Users\beades\Desktop\Remote Work\My Packages\Package 421696 (Bonanza 24-34)\12WE3163.CP7
Separator Venting Emissions Inventory
Emission Factors Separator Venting Separator Venting
Uncontrolled Controlled Uncontrolled Controlled
Emission Factor Source Emission Factor Source
Pollutant (lb/MMscf) (lb/MMscf) (lb/MMscf) (Ib/MMscf)
(Gas Throughput) (Gas Throughput) (Gas Throughput) (Gas Throughput)
VOC 103277.6458 2065.5529 43022.0942 860.4419
Benzene 213.5850 4.2717 62.4150 1.2483
Toluene 167.5253 3.3505 56.4747 1.1295
Ethylbenzene 15.7547 0.3151 Extended gas analysis (VRT) 5.6893 0.1138 Extended gas analysis (LP Separator)
Xylene 61.5303 1.2306 23.4265 0.4685
n-Hexane 2021.2128 40.4243 529.6072 10.5921 _
224 TMP _ 1.1165 0.0223 0.3347 _ 0.0067
Separator Venting (WEIGHTED EF) FOR COMMINGLED STREAM
Uncontrolled Controlled
Emission Factor Source
Pollutant (lb/MMscf) (Ib/MMscf)
(Gas Throughput) (Gas Throughput)
VOC 73149.8700 1462.9974
Benzene 138.0000 2.7600
Toluene 112.0000 2.2400 Weighted factors for commingled stream
Ethylbenzene 10.7220 0.2144
Xylene 42.4784 0.8496
n-Hexane - 1275.4100 25.5082
224 TMP 0.7256 0.0145
Primary Control Device
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source
(Waste Heat
Combusted) (Gas Throughput)
PM10 _ _ 0.0075 16.3698 AP-42 Table 1.4-2 (PM10/PM.2.5)
PM2.5 0.0075 16.3698 AP-42 Table 1.4-2 (PM10/PM.2.5)
SOx 0.0006 1.2924 AP-42 Table 1.4-2 (50x)
NOx 0.0680 149.3960 AP-42 Chapter 13.5 Industrial Flares (NOx)
CO 0.3100 681.0700 AP-42 Chapter 13.5 Industrial Flares (CO)
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source
(Waste Heat
Combusted) (Pilot Gas Throughput)
PM10 0.0075 19.3480 AP-42 Table 1.4-2 (PM10/PM.2.5)
PM2.5 0.0075 19.3480 AP-42 Table 1.4-2 (PM10/PM.2.5)
SOx 0.0006 1.5275 AP-42 Table 1.4-2 (SOx)
NOx 0.0980 254.5784 AP-42 Table 1.4-1 (NOx)
CO 0.0824 213.8459 AP-42 Table 1.4-1 (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 _ 0.1 0.1 0.1 0.1 0.1 17
PM2.5 0.1 0.1 0.1 0.1 0.1 17
SOx 0.0 0.0 0.0 0.0 0.0 1
NOx 0.9 0.9 0.9 0.92 0.92 155
VOC 438.9 438.9 8.8 438.90 8.78 1491
CO 4.1 4.1 4.1 4.10 4.10 697
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year)
Benzene 1656 1656 33 1656 33
Toluene 1344 1344 27 1344 27
Ethylbenzene 129 129 3 129 3
Xylene 510 510 10 510 10
n-Hexane 15305 15305 306 153O5 306
224 TMP 9 9 0 9 0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B Source requires a permit
Regulation 7, Section XVII.B, G Source is subject to Regulation 7, Section XVII.B.2, G
Regulation 7, Section XVII.B.2.e The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
12 of 17 C:\Users\beades\Desktop\Remote Work\My Packages\Package 421696 (Bonanza 24-34)\12WE3163.CP7
Separator Venting Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Does the company use site specific emission factors based on a gas sample to estimate emissions? Yes
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 90 tons per year?
If yes, the permit will contain:
-An "Initial Testing Requirement" to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less
than or equal to the emissions factors established with this application.
-A "Periodic Testing Requirement" to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less
than or equal to the emissions factors established with this application on an annual basis.
Will the operator have a meter installed and operational upon startup of this point? Yes
If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This
condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain compliance testing requirements to demonstrate the destruction efficiency of the combustion device based on
inlet and outlet concentration sampling
You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer.
,i�� y
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If no. ',re per'r-tlit •eta i!'i:'c� r': initial Compliance Lrt � � �;:_; `f. P .` �f. ri"...c ...t ' . .. 'i s. .a .i..�,c\t, • : ..' f .'S
f.;f ^ 1• r c . ICnr f ),(� tit 6 i>v�^ r :.1r T;u.T f: jt tt,_; ♦ r , e-t ' y'` '' <J t S.
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1 ` i WI L {:3,: i( 5• ., e t.._ _ iL,,. .r;. ! f.+' {{�:..• r .Y ., +? + f. _ �; �: ! .i..t v(.'t! :/
t L i ', �`{ i4 1 _ .l. ,i 1.:L' k Ly ., .I-.•✓� lt., vi
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,y • a �[ i, ₹ Y �l lit UL to �a�irsLc- ,3t-,� i kl �. � i li kt,r ^≤ � r 4 ;ft d••
•
Section 08 - Technical Analysis Notes
As indicated in the emission calculation methodology in Section 03 above, the source is using a weighted gas composition of a commingled V RT and LP gas stream to the combustor. The commingled composition assumes a 50/50 split of VRT to LP
separator gas (i.e. 6 MMSCF/yr LP gas & 6 MMSCF/yr VRT gas). Source will meter the commingled stream and further indicates that LP separator gas and VRT gas will always be simulataneously be routed to the combustor such that the stream to the
combustor always be commingled gas. To enable this grouping strategy, the source has agreed to semi-annual testing of the commingled vapor stream to demonstrate emission factors have not increased.
This vapor stream is routed to a dedicated combustor. Pilot emissions are accounted for with this point and are based on a pilot flow of 16.8 scfh and conservatively based on VRT gas composition for HHV.
Applicant will be required to comply with monitoring and sampling requirements in PS MEmo 20-02 since 98% control is requested. Upon review of the draft permit, the applicant indicated that they had not previously designed the plant to
accomodate the hourly pilot light monitoring/recording. However, applicant indicated that facility is equipped with an automa ted pilot flame sensor that shuts in the producing wells whenever a flame is not detected. Source will continue to monitor
the pilot for presence of a flame on a weekly basis and document the status. Applicant agrees to calculate actual emissions a ssuming 0% control for the duration of any observed pilot outtage from the time of the observed outtage to the last
confirmed operational pilot (up to 1 week prior).
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point # Process # SCC Code Pollutant Uncontrolled Emissions Factor Control % Units
013 01 3-10-001-60 Flares PM10 16.4 0 Ib/MMSCF
PM2.5 16.4 0 lb/MMSCF
SOx 1.3 0 Ib/MMSCF
NOx 149.4 0 ib/MMSCF
VOC 73149.9 98 Ib/MMSCF
CO 681.1 0 Ib/MMSCF
Benzene 138.0 98 Ib/MMSCF
Toluene 112.0 98 Ib/MMSCF
Ethylbenzene 10.7 98 Ib/MMSCF
Xylene 42.5 98 Ib/MMSCF
n-Hexane 1275.4 98 Ib/MMSCF
224 TMP 0.7 98 Ib/MMSCF
13 of 17 C:\Users\beades\Desktop\Remote Work\My Packages\Package 421696 (Bonanza 24-34)\12WE3163.CP7
Separator Venting Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and B - APEN and PermitRequirements
Source is in the Non-Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)'
2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
You have indicated that source is in the Non-Attainment Area
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? Yes ": Source Re
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Yes Source Re
Source requires a permit
Colorado Regulation 7. Section XVII
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? Yes Source is
Source is subject to Regulation 7, Section XVII.B.2, G
Section XVII.B.2 —General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.G - Emissions Control
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 contr.
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
Section XVII.B.2.e— Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing
regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non-mandatory language such as "recommend, " "may," "should,"and "can,"is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must"and "required"are intended to describe controlling requirements under the terms of the Clean Air
Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
Company Name Bonanza Creek Energy
County AIRS ID 123 History File Edit Date 17 April 2020
Plant AIRS ID 9A82 Ozone Status Non-Attainment
Facility Name North Platte 24-34 Production Facility
EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year)
POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS
AIRS ID VOC HAPs VOC HAPs
Previous FACILITY TOTAL 1.7 1.7 0.0 0.0 20.9 68.4 0.5 40.2 7.4 From July 2019 tab
Previous Pennitted Facility total 1.3 1.3 0.0 0.0 16.2 63.0 0.0 36.3 7.2
001 12WE3163 Eight 803 barrel condensate tanks 0.5 255.5 2.3 5.3 0.5 12.8 2.3 , 0.3 Mod add produ-'
002 12WE3163 Condensate loadout 0.1 45.0 0 3 1.0 0.1 2.3 0.3 0.1 Mod add product , _
003 12WE3163 Fugitives 0.0 0.0 CM received 7/8/15 _
004 GP02 RICE 0.0 0.0 CN received 1/22/16
005 GP02 RICE 0.0 0.0 CN received 7/11/18
006 GP02 RICE 0.0 0.0 CN received 2/12./15
007 GP02 VRU Compressor 0.0 i 0.0 CN received 8/18/16
008 GP02 VRU Compressor 0.0 0.0 CN received 4/6/16
009 GP02 VRU Compressor 0.0 0.0 CN received 11/10/16
0.0 2.5 0 0 0.0 0.2 0.0
010 12WE3163 Two 400 barrel produced water tanks 0.0 0.0 Mod (CN received previously for source below
thresholds, however emissions have increased)
011 12WE3163 Emergency flare 0.0 0.0 CN received 9/6/16
012 12WE3163 Temporary flare 0.0 0.0 CN recevied 7/9/15
013 12WE3163 LPNRT separator venting 0.1 0.1 0.9 438.8 4.1 9.3 0.1 0 1 0.9 8 8 4.1 0.2 Mod new sample aniayses, combine VRT and LP
98% control
014 12WE3163 VRT venting 0.0 0.0 CN received 9/6/16
015 GP02 RICE 0.0 0.0 CN received 5/23/16
016 12WE3163 Sandpiper G1F pump - 0.0 0.0 CN received 11/30/17
017 12WE3163 TEG Dehy 0.1 ' 42.5 0.5 25.1 0.1 2.1 0.5 1.1
018 GP02 RICE - Waukesha F3524GSl 0.6 0.6 126.6 5.7 103.9 2.6 0 6 0.6 8.2 5.7 16.3 2.6 No change
019 GP02 RICE - Waukesha F2895GSl 0.5 0.5 76.2 4.1 52.8 0.6 0.5 0.5 4.1 4.1 8.8 0.6 No change
020 GP02 RICE 85 Hp 0.1 0.1 3.7 0.2 6.3 0.0 0 1 0.1 2.3 0.2 4.0 0.0 No change
APEN Exempt/Insigniticant Sources
XA Heated Separators 0.4 0.4 4.7 0.3 3.9 0.1 0 4 0.4 4.7 0.3 3.9 0.1 Per APCD102
XA Pneumatic Devices 1 7.1 0.1 7.1 0.1 Per APCD102
XA Fugitive Equipment Leaks 0.6 0.0 0.6 0.0 Per APCD102
XA Compressor Blowdown 0.4 0.0 0.4 0.0 Per APCD102
VOC: Syn Minor (NANSR and OP)
NOx: Syn Minor(NANSR and OP)
FACILITY TOTAL 1.7 1.7 0.0 0.0 212.8 802.2 0.6 174.2 45.2 1 .7 1.7 0.0 0.0 20.9 44.0 0.6 40.3 5.1 CO: Syn Minor (OP)
HAPS: Syn Minor n-Hex & Total (OP)
HH: Area
7777: Area
Permitted Facility Total 1.3 1.3 0.0 0.0 16.2 36.2 0.0 36.4 4.9 Excludes units exempt from permits/APENs
(A) Change in Permitted Emissions 0.0 0.0 0.0 0.0 0.0 -26.8 0.0 0.1 Pubcom & modeling not required for change in
emissions
Total VOC Facility Emissions (point and fugitive) 44.6 Facility is eligible for GP02 because < 90 tpy
(A) Change in Total Permitted VOC emissions (point and fugitive) -26.8 Project emissions less than 25/50 tpy
Note 1
Note 2
Company Name Bonanza Creek Energy
County AIRS ID 123
Plant AIRS ID 9A82
Facility Name North Platte 24-34 Production Facility
Emissions - uncontrolled lbs per year)
POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP TOTAL (tpy)
001 12WE3163 Eight 803 barrel condensate tanks 1295 1124 318 9821 2,_' 6.3
002 12WE3163 Condensate loadout 1 .1_ r• 1766 1.0
003 12WE3163 Fugitives
004 GP02 RICE 0.0
005 GP02 RICE f 0.0
006 GP02 RICE
007 GP02 VRU Compressor
008 GP02 VRU Compressor
009 GP02 VRU Compressor
010 12WE3163 Two 400 barrel produced water tanks I 279
011 12WE3163 Emergency flare I
012 12WE3163 Temporary flare
013 12WE3163 LPNRT separator venting 1656 1344 510 15036 9.3
014 12WE3163 VRT venting
015 GP02 RICE
016 12WE3163 Sandpiper G1 F pump 0.0
017 12WE3163 TEG Dehy 10642 15489 4367 15784 3698 283 25.1
018 GP02 RICE - Waukesha F3524GSI 4542 163 92 t 11 178 2.6
019 GP02 RICE - Waukesha F2895GSI 586 150 1,t1 85 164 0.6
020 GP02 RICE 85 Hp 0.0
0.0
0.0
APEN Exempt/Insignificant Sources 0.0
0.0
XA Heated Separators 148 0.1
XA Pneumatic Devices 1 15 107 : 0.1
XA Fugitive Equipment Leaks 7 21 0.0
XA Compressor Blowdown 1 4 0.0
0.0
0.0
0.0
TOTAL (tpy) 2.6 0.2 0.1 7.1 9.1 2.3 8.4 15.4 0.2 0.2 45.5
Emissions with controls (lbs per year)
POINT PERMIT Description Formaldehyde Acetaldehyde I Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP TOTAL (tpy)
001 12WE3163 Eight 803 barrel condensate tanks r. 1-, 491 0.3
002 12WE3163 Condensate loadout c 1 _ 0.1
003 12WE3163 Fugitives
004 GP02 RICE 0.0
005 GP02 RICE 0.0
006 GP02 RICE - _ _ _
007 GP02 VRU Compressor
008 GP02 VRU Compressor
009 GP02 VRU Compressor I
010 12WE3163 Two 400 barrel produced water tanks ..
011 12WE3163 Emergency flare
012 12WE3163 Temporary flare
013 12WE3163 LPNRT separator venting I 1 ; 0.2
014 12WE3163 VRT venting
015 GP02 RICE
016 12WE3163 Sandpiper G1F pump 0.0
017 12WE3163 TEG Dehy 495 736 211 772 63 5 1.1
018 GP02 RICE - Waukesha F3524GS1 4542 163 15-3 1 178 2.6
019 GP02 RICE - Waukesha F2895GS1 586 150 141 _ : 164 0.6
020 GP02 RICE 85 Hp 0.0
0.0
0.0
/Insignificant Sources 0.0
0.0
XA Heated Separators 148 0.1
XA Pneumatic Devices 1 15 107 10.1
XA Fugitive Equipment Leaks 7 _ 2. 21 0.0
XA Compressor Slowdown 1 4 0.0
0.0
0.0
0.0
TOTAL (tpy) 2.6 0.2 0.1 0.4 0.4 0.1 0.4 0.6 0.2 0.1 5.1
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