HomeMy WebLinkAbout20202353.tiff C COLORADO
Department of Public
Health&Environment
RECEIVED
Weld County - Clerk to the Board
1150 O St JUL 2 3 2020
PO Box 758
Greeley, CO 80632 COMMISSIONERS�
July 20, 2020
Dear Sir or Madam:
On July 21, 2020, the Air Pollution Control Division will begin a 30-day public notice period for
Bonanza Creek Energy Operating Company, LLC - Antelope Section 19 Compressor Station. 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
o co(o
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Z S,
Jared Potts, Governor I Jill Hunsaker Ryan,MPH, Executive Director #. ,.,,.l
Pu b I:G Re v:e w CC:MOP),HI-(Ds),PW(SM/ER/cH/tK), 2020-2353
of/o5/2o OG4ar1)
07/2 91.20
M�M,M Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
cDPHE
Comment
Website Title: Bonanza Creek Energy Operating Company, LLC - Antelope Section 19 Compressor Station -
Weld County
Notice Period Begins: July 21, 2020
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: Bonanza Creek Energy Operating Company, LLC
Facility: Antelope Section 19 Compressor Station
Compressor Station
SESE Sec 19 T5N R62W
Weld County
The proposed project or activity is as follows: This source is adding the condensate tanks to this facility-
wide permit (from a GP01 permit), adding controls to the tank loading operations, and updating the
operating parameters and corresponding emissions for the dehydrator onsite. This is an existing facility. This
facility is synthetic minor for NOx, VOC, CO, and HAPs (Total, n-hexane, benzene, toluene, xylene). The
permitted, controlled emissions at this facility are greater than 40 tpy VOC.
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 12WE1563 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:
Lauraleigh Lakocy
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
Department of Public
- 1 1je.4,7iii
0°" Health Er Environment
r COLORADO
N®/ Mr 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: 12WE1563 Issuance: 7
Date issued:
Bonanza Creek Energy Operating
Issued to: Company, LLC
Facility Name: Antelope Section 19 Compressor Station (COGCC #427983)
Plant AIRS ID: 123/9813
Physical Location: SESE SEC 19 T5N R62W
County: Weld County
General
Description: Natural Gas Compressor Station
Equipment or activity subject to this permit:
Equipment AIRS Equipment Description Emissions Control
ID Point Description
L-01 001 Truck loadout of condensate by Enclosed Combustion
submerged fill using vapor balance Devices
One (1) 300 barrel and two (2) 500 Enclosed Combustion
CNDTK-01 002 barrel fixed roof storage vessels used Devices
to store condensate
One (1) Triethylene glycol (TEG),
natural gas dehydration unit (QB Emissions from the still
Johnson Manufacturing, serial number: vent are routed to an air-
769318) with a design capacity of 30 cooled condenser and then
MMscf per day. This emissions unit is to the enclosed
DEHY-01 018 equipped with one (1) primary and one combustion device.
(1) backup Kimray PV45015 glycol Emissions from the flash
pumps with a design capacity of 7.5 tank are directly recycled
gallons per minute. This unit is to plant inlet through a
equipped with a flash tank, reboiler closed loop system.
and still vent.
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 19
G.4
rk.} COLORADO
Air Pollution Control Division
<OWE
Department of Public Health&Environment
Dedicated to protecting and improving the hearth and environment of the people of Colorado
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. 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.)
2. This permit must expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
F.4.)
3. 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.)
4. 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.
EMISSION LIMITATIONS AND RECORDS
5. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4)
Annual Limits:
Equipment ID AIRS Tons per Year Emission
Point PM2.5 NO. VOC CO Type
L-01 001 --- --- 0.4 --- Point
CNDTK-01 002 -- --- 15.2 2.8 Point
DEHY-01 018 --- --- 8.5 1.2 Point
Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per
year.
Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Page 2 of 19
Cr: M COLORADO
44,0, 0 Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
6. Points 001, 002:The owner or operator must use the emission factors found in "Notes to Permit
Holder" to calculate emissions and show compliance with the limits. The owner or operator
must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the
use of any other method of calculating emissions.
7. Point 018: 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: dry gas throughput, lean glycol
recirculation rate, 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.
8. Point 018: On a daily basis, the owner or operator shall monitor and record operational values
including: wet gas inlet temperature and pressure. These records shall be maintained for a
period of five years.
9. The owner or operator must track emissions from all insignificant activities at the facility on an
annual basis to demonstrate compliance with the facility potential emission limitations as
indicated below. An inventory of each insignificant activity and associated emission calculations
must be made available to the Division for inspection upon request. For the purposes of this
condition, insignificant activities are defined as any activity or equipment, which emits any
amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt.
(Regulation 3, Part C. II.E.)
Total potential emissions from the facility, including all permitted emissions and potential to
emit from all insignificant activities, must be less than:
• 50 tons per year of VOC.
10. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Equipment AIRS Control Device Pollutants Controlled
ID Point
L-01 001 Enclosed Combustion Devices VOC and HAP
CNDTK-01 002 Enclosed Combustion Devices VOC and HAP
DEHY-01 018 Still Vent: Enclosed VOC and HAP
Combustion Device
Page 3 of 19
r•:, COLORADO
40 NiviP Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
11. The owner or operator shall operate and maintain the emission points in the table below as a
closed loop system and shall recycle 100% of emissions as described in the table below.
(Regulation Number 3, Part B, Section III.E.)
Equipment AIRS Emissions Recycling Description Pollutants
ID Point Recovered
DEHY-01 018 Flash Tank: Recycled to Fuel Gas System or VOC and HAP
Plant Inlet
PROCESS LIMITATIONS AND RECORDS
12. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rate must be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, Section
II.A.4)
Process/Consumption Limits
Equipment AIRS Process Process Parameter Annual Limit
ID Point
L-01 001 -- Condensate Loaded 61,320 barrels
CNDTK-01 001 01 Condensate Throughput 61,320 barrels
02 Combustion of pilot light gas 0.81 MMSCF
DEHY 01 018 01 Dry Gas Throughput 10,950 MMSCF
02 Combustion of pilot light gas 0.2 MMSCF
The owner or operator must calculate monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
13. Point 018: This unit shall be limited to the maximum lean glycol circulation rate of 7.5 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 (Loft) provisions under MACT HH. (Reference: Regulation Number 3, Part B,
II.A.4)
Page 4 of 19
r COLORADO
Air Pollution Control Division 1n
Department of Public Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
STATE AND FEDERAL REGULATORY REQUIREMENTS
14. 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.)I.E.) (State only enforceable)
15. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the
source. During periods of startup, process modification, or adjustment of control equipment
visible emissions shall not exceed 30%opacity for more than six minutes in any sixty consecutive
minutes. (Regulation Number 1, Section II.A.1. Et 4.)
16. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
17. Point 001: 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.)
a. Facilities constructed or modified on or after May 1, 2020, must be in compliance by
commencement of operation.
b. Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021.
c. 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.
18. Point 001: Storage tanks must operate without venting at all times during loadout. (Regulation
Number 7, Part D, Section II.C.5.a.(ii))
19. Point 001: The owner or operator must, as applicable (Regulation Number 7, Part D, Section
II.C.5.a.(iii)):
a. 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.
b. Include devices to prevent the release of vapor from vapor recovery hoses not in use.
c. Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to
transport vehicles unless the vapor collection and return system is in use.
d. Operate all recovery and disposal equipment at a back-pressure less than the pressure
relief valve setting of transport vehicles.
e. The owner or operator must inspect onsite loading equipment to ensure that hoses,
couplings, and valves are maintained to prevent dripping, leaking, or other liquid or
vapor loss during loadout. These inspections must occur at least monthly, unless loadout
occurs less frequently, then as often as loadout is occurring.
Page 5 of 19
C ,, ,,,e.....:::-. COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
20. Point 001: The owner or operator must perform the following observations and training
(Regulation Number 7, Part D, Section II.C.5.a.(iv)):
a. 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,
b. 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.
c. 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.
d. 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.
21. Point 001: 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.
a. Records of the annual facility hydrocarbon liquids loadout to transport vehicles
throughput.
b. 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.
c. Records of the infeasibility of observation of loadout.
d. Records of the frequency of loadout.
e. Records of the annual training program, including the date and names of persons
trained.
22. Point 001: Air pollution control equipment used to comply with this Section II.C.5. must comply
with Section II.B., be inspected in accordance with Sections II.C.1.d.(ii) through (v), and
achieve a hydrocarbon control efficiency of 95%. (Regulation Number 7, Part D, Section
II.C.5.a.(vi))
23. Point 002: 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
Page 6 of 19
COLORADO
410 C+-"10, Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
means approved by the Division, determine whether it is operating properly. (Regulation
Number 7, Part D, Section I.C.) (State only enforceable)
24. Point 002: The combustion device covered by this permit is subject to Regulation Number 7,
Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion
device is used to control emissions of volatile organic compounds to comply with Section II, it
must be enclosed; have no visible emissions during normal operations, as defined under
Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by
means of visual observation from the outside of the enclosed flare or combustion device, or by
other convenient means approved by the Division, determine whether it is operating properly.
This flare must be equipped with an operational auto-igniter according to the schedule in
Regulation Number 7, Part D, Section II.B.2.d.
25. Point 002: 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.
26. Point 002: 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.
27. Point 002:The storage tanks covered by this permit are subject to the New Source Performance
Standards requirements of Regulation Number 6, Part A, Subpart Kb, Standards of Performance
for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for
which Construction, Reconstruction, or Modification Commenced after July 23, 1984 including,
but not limited to, the following (Regulation Number 6, Part A, Subparts A and Kb):
• 40 CFR, Part 60, Subpart A - General Provisions
• §60.112b - Standard for volatile organic compounds (VOC)
• §60.112b(a) The owner or operator of each storage vessel either with a design
capacity greater than or equal to 151 m3 containing a VOL that, as stored, has a
maximum true vapor pressure equal to or greater than 5.2 kPa but less than 76.6
kPa or with a design capacity greater than or equal to 75 m3 but less than 151 m3
containing a VOL that, as stored, has a maximum true vapor pressure equal to or
greater than 27.6 kPa but less than 76.6 kPa, shall equip each storage vessel with
one of the following:
• §60.112b(a)(3) A closed vent system and control device meeting the
following specifications:
• §60.112b(a)(3)(i)The closed vent system shall be designed to collect all VOC
vapors and gases discharged from the storage vessel and operated with no
Page 7 of 19
it4. , COLORADO
Mr Pollution Control Division
�i� Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
detectable emissions as indicated by an instrument reading of less than 500
ppm above background and visual inspections, as determined in part 60,
subpart W, §60.485(b).
• §60.112b(a)(3)(ii) The control device shall be designed and operated to
reduce inlet VOC emissions by 95 percent or greater. If a flare is used as the
control device, it shall meet the specifications described in the general
control device requirements (S60.18) of the General Provisions.
• §60.113b - Testing and procedures
• §60.113b(c) The owner or operator of each source that is equipped with a closed
vent system and control device as required in §60.112b (a)(3) or (b)(2) (other than a
flare) is exempt from §60.8 of the General Provisions and shall meet the following
requirements.
• $60.113b(c)(1) Submit for approval by the Administrator as an attachment
to the notification required by §60.7(a)(1) or, if the facility is exempt from
§60.7(a)(1), as an attachment to the notification required by §60.7(a)(2), an
operating plan containing the information listed below.
• §60.113b(c)(1)(i) Documentation demonstrating that the control device will
achieve the required control efficiency during maximum loading conditions.
This documentation is to include a description of the gas stream which enters
the control device, including flow and VOC content under varying liquid level
conditions (dynamic and static) and manufacturer's design specifications for
the control device. If the control device or the closed vent capture system
receives vapors, gases, or liquids other than fuels from sources that are not
designated sources under this subpart, the efficiency demonstration is to
include consideration of all vapors, gases, and liquids received by the closed
vent capture system and control device. If an enclosed combustion device
with a minimum residence time of 0.75 seconds and a minimum temperature
of 816 °C is used to meet the 95 percent requirement, documentation that
those conditions will exist is sufficient to meet the requirements of this
paragraph.
• $60.113b(c)(1)(ii) A description of the parameter or parameters to be
monitored to ensure that the control device will be operated in conformance
with its design and an explanation of the criteria used for selection of that
parameter (or parameters).
• $60.113b(c)(2) Operate the closed vent system and control device and
monitor the parameters of the closed vent system and control device in
accordance with the operating plan submitted to the Administrator in
accordance with paragraph (c)(1) of this section, unless the plan was
modified by the Administrator during the review process. In this case, the
modified plan applies.
• §60.115b - Reporting and recordkeeping requirements
• The owner or operator of each storage vessel as specified in §60.112b(a) shall keep
records and furnish reports as required by paragraphs (a), (b), or (c) of this section
Page 8 of 19
r7Ms COLORADO
110 C
N ;11/ Air Pollution Control Division
�� Department of Public Heath&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
depending upon the control equipment installed to meet the requirements of
§60.112b. The owner or operator shall keep copies of all reports and records required
by this section, except for the record required by (c)(1), for at least 2 years. The
record required by (c)(1) will be kept for the life of the control equipment.
• $60.115b(c) After installing control equipment in accordance with §60.112b (a)(3)
or (b)(1) (closed vent system and control device other than a flare), the owner or
operator shall keep the following records.
• $60.115b(c)(1) A copy of the operating plan.
• $60.115b(c)(2)A record of the measured values of the parameters monitored
in accordance with §60.113b(c)(2).
• $60.116b -Monitoring of operations
• §60.116b(a) The owner or operator shall keep copies of all records required by this
section, except for the record required by paragraph (b) of this section, for at least
2 years. The record required by paragraph (b) of this section will be kept for the life
of the source.
- $60.116b(b) The owner or operator of each storage vessel as specified in
§60.110b(a) shall keep readily accessible records showing the dimension of the
storage vessel and an analysis showing the capacity of the storage vessel.
• §60.116b(g) The owner or operator of each vessel equipped with a closed vent
system and control device meeting the specification of §60.112b or with emissions
reductions equipment as specified in 40 CFR 65.42(b)(4), (b)(5), (b)(6), or (c) is
exempt from the requirements of paragraphs (c) and (d) of this section.
In addition, the following requirements of Regulation No. 6, Part A, Subpart A, General
Provisions, apply.
a. At all times, including periods of start-up, shutdown, and malfunction, the facility and
control equipment shall, to the extent practicable, be maintained and operated in a
manner consistent with good air pollution control practices for minimizing emissions.
Determination of whether or not acceptable operating and maintenance procedures are
being used will be based on information available to the Division, which may include,
but is not limited to, monitoring results, opacity observations, review of operating and
maintenance procedures, and inspection of the source. (Reference: Regulation No. 6,
Part A. General Provisions from 40 CFR 60.11
b. No article, machine, equipment or process shall be used to conceal an emission which
would otherwise constitute a violation of an applicable standard. Such concealment
includes, but is not limited to, the use of gaseous diluents to achieve compliance with
an opacity standard or with a standard which is based on the concentration of a pollutant
in the gases discharged to the atmosphere. (S 60.12)
c. Written notification of construction and initial startup dates shall be submitted to the
Division as required under § 60.7.
d. Records of startups, shutdowns, and malfunctions shall be maintained, as required under
§ 60.7.
Page 9 of 19
Cr COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
e. Written notification of opacity observation or monitor demonstrations shall be
submitted to the Division as required under § 60.7.
f. Excess Emission and Monitoring System Performance Reports shall be submitted as
required under § 60.7.
g. Performance tests shall be conducted as required under § 60.8.
h. Compliance with opacity standards shall be demonstrated according to § 60.11.
28. Point 018: This source is subject to Regulation Number 7, Part D, Section I.H. The operator
shall comply with all applicable requirements of Section I 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, Part D, Section I.H.1.)
29. Point 018: The combustion device covered by this permit is subject to Regulation Number 7,
Part D, Section II.B General Provisions (State only enforceable). If a flare or other combustion
device is used to control emissions of volatile organic compounds to comply with Section II, it
shall be enclosed; have no visible emissions during normal operations, as defined under
Regulation Number 7, Part D, II.A.23; and be designed so that an observer can, by means of
visual observation from the outside of the enclosed flare or combustion device, or by other
convenient means approved by the Division, determine whether it is operating properly. This
flare must be equipped with an operational auto-igniter according to the 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.
30. Point 018: The glycol dehydration unit covered by this permit is subject to the emission control
requirements in Regulation Number 7, Part D, Section II.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 II.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.
31. Point 018: 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 provisions of this
regulation, as stated in 40 C.F.R Part 63, Subpart A and HH. (Regulation Number 8, Part E,
Subpart A and HH)
Page 10 of 19
C ,, ,,,,,,....r.{M,- COLORADO
Air Pollution Control Division
cDP is
Department of Public Health&EnWonment
Dedicated to protecting and improving the health and environment of the people of Colorado
MACT HH Applicable Area Source
Requirements Benzene emissions exemption
563.764 (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
563.764 - General the records of the determination of these criteria must be
Standards maintained as required in §63.774(d)(1).
563.764 (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
§63.764(e)(1).
§63.772(b)(2) - The determination of actual average benzene
emissions from a glycol dehydration unit shall be made using the
procedures of either paragraph (b)(2)(i) or (b)(2)(ii) of this
section. Emissions shall be determined either uncontrolled, or
with federally enforceable controls in place.
563.772 - 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-GLYCaIc 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.
563.774 (d)(1) - An owner or operator of a glycol dehydration
563.774 - unit that meets the exemption criteria in §63.764(e)(1)(i) or
Recordkeeping §63.764(e)(1)(ii) shall maintain the records specified in paragraph
Requirements (d)(1)(i) or paragraph (d)(1)(ii) of this section, as appropriate, for
that glycol dehydration unit.
Page 11 of 19
: COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
563.774 (d)(1)(ii) - The actual average benzene emissions (in
terms of benzene emissions per year) as determined in
accordance with $63.772(b)(2).
32. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division-approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING Et MAINTENANCE REQUIREMENTS
33. Point 001, 002, 018: Upon startup of these points, the owner or operator must follow the
most recent operating and maintenance (0&tM) plan and record keeping format approved by
the Division, in order to demonstrate compliance on an ongoing basis with the requirements
of this permit. Revisions to your OEtM plan are subject to Division approval prior to
implementation. (Regulation Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
34. Point 002: The owner or operator must demonstrate compliance with opacity standards, using
EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence
of visible emissions. "Visible Emissions" means observations of smoke for any period or periods
of duration greater than or equal to one minute in any fifteen-minute period during normal
operation. (Regulation Number 7, Part D, Sections I.C, II.B.2. and II.A.23)
Periodic Testing Requirements
35. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
36. All previous versions of this permit are cancelled upon issuance of this permit.
37. This permit replaces the following permits and/or points, which are cancelled upon issuance of
this permit.
Page 12 of 19
Tr COLORADO
40 il..hiretulll Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Existing Permit Existing New Emission Point
Number Emission Point
GP01 123/9813/002 123/9813/002
38. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
Section II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX 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.
For any non-criteria reportable pollutant:
If the emissions increase by 50%or five(5) tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
39. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source must not exceed the Federal program threshold until a
permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
40. 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
Page 13 of 19
COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
41. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self-certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self-Certify for Final Authorization section of this permit.
42. 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.
43. 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.
44. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
45. 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.
46. 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.
Page 14 of 19
COLORADO
je. .44 Air Pollution Control Division
Department of Pubhc Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
By:
Lauraleigh Lakocy
Permit Engineer
Permit History
Issuance Date Description
Issued to Bonanza Creek Operating Company
Issuance 1 October 26, 2012 LLC. Newly permitted loadout at synthetic
minor facility.
Issuance 2 April 22, 2014 Issued to Bonanza Creek Operating Company
LLC. For the addition of two heat trace pumps.
Issued to Bonanza Creek Energy Operating
Issuance 3 September 29, 2014 Company LLC. Addition of Fugitive Emissions to
Permit.
Issued to Bonanza Creek Energy Operating
Issuance 4 September 20, 2016 Company LLC. Consolidate pump associated with
AIRS 014 to AIRS 013.
Issuance 5 July 13, 2017 Issued as final approval. Removed point 013.
Issued to Bonanza Creek Energy Operating
Issuance 6 November 1, 2018 Company, LLC. Addition of Point 018 - TEG
Dehydrator. Issued as initial approval
modification.
Issued to Bonanza Creek Energy Operating
Company, LLC
Point 001: Updated emission factors, added
Issuance 7 This Issuance controls
Point 002: Added to permit
Point 018: Updated operating parameters and
associated emissions
Page 15 of 19
�r.:. COLORADO
4.
�/ 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 following emissions of non-criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS Uncontrolled Controlled
Point Pollutant CAS # Emissions Emissions
(lb/yr) (lb/yr)
001 n-Hexane 110543 698 36
Benzene 71432 2,132 107
002 Toluene 108883 1,061 53
n-Hexane 110543 18,773 939
Benzene 71432 39,482 1,887
Toluene 108883 48,524 2,357
018 Ethylbenzene 100414 11,780 579
Xylenes 1330207 46,900 2,318
n-Hexane 110543 11,549 243
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Page 16 of 19
C wi, COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
Point 001:
Uncontrolled Controlled
Pollutant CAS # Emission Factors Emission Source
lb/bbl Factors
lb/bbl
AP-42, Chapter 5.2,
VOC 0.252 1.26E-02 Equation 1 Et Site-
specific stable oil
n-Hexane 110543 0.0114 5.7E-04 sample taken
7/1/2018
The uncontrolled VOC 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
S = 0.6 (Submerged loading: dedicated normal service)
P (true vapor pressure) = 6.78 psia
M (vapor molecular weight) = 62.77 lb/lb-mot
T (temperature of liquid loaded) = 524 °R
The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by
multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor.
Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of
100%.
Point 002:
Process 01: Condensate Throughput
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
CO 0.0794 0.0794 AP-42, Chapter
13.5
VOC 9.93 0.4965 ProMax
71432 Benzene 0.035 1.75E-03 Simulation based
108883 Toluene 0.017 8.5E-04 on site-specific
pressurized
110543 n-Hexane 0.306 1.53E-02 liquid sample
• taken 2/15/2019
Note: The controlled emissions factors for this point are based on a control efficiency of 95%. •
Page 17 of 19
AOIlk r COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Process 02: Pilot Light Combustion
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/MMSCF lb/MMSCF
CO 813.44 813.44 AP-42, Chapter
13.5
Note:The CO emission factors listed in the table above were obtained by multiplying the AP-42 Chapter 13.5 CO
emission factor(0.31 lb/MMBtu) by a heat value of 2,624 Btu/scf. Actual emissions are calculated by multiplying the
emission factors in the table above by the total fuel flow of the pilot gas. Pilot light fuel flow is based on a constant
rate of 18.5 scf/hr. There are a total of five(5)combustors used to control emissions from the condensate storage
vessels. As a result, the total pilot gas fuel flow is 92.5 scf/hr.
Point 018:
Process 01: Dry Gas Throughput
The emission levels contained in this permit are based on information provided in the application
and the GRI GlyCalc 4.0 model. The model was based on an inlet gas temperature of 100°F and a
pressure of 800 psig, glycol recirculation rate is 7.5 gallons per minute and flash tank
temperature of of 120°F and a pressure of 120 psig. Flash tank emissions are 100% recycled.
Controlled still vent emissions are based on a flare control efficiency of 95%.
Still vent combustion emissions are based on the following emission factors:
Still Vent Primary Control:
Uncontrolled
CAS # Pollutant Emission Factors Source
lb/MMscf Waste
Gas Combusted
CO 108.56 AP-42, Chapter
13.5
Note: The combustion emission factors are based on a heating value of 350 Btu/scf. Actual emissions are calculated by
multiplying the emission factors in the table above by the waste gas flow from the regenerator overheads stream in the
monthly GlyCalc report and by the hours per month the waste gas was routed to this control device.
Process 02: Pilot Light Combustion
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/MMSCF lb/MMSCF
CO 432.45 432.45 AP-42, Chapter
13.5
Note:The CO emission factors listed in the table above were obtained by multiplying the AP-42 Chapter 13.5 CO
emission factor(0.31 lb/MMBtu) by a heat value of 1,395 Btu/scf. Actual emissions are calculated by multiplying the
emission factors in the table above by the total fuel flow of the pilot gas. Pilot light fuel flow is based on a constant
rate of 18.5 scf/hr. There is a single combustors used to control emissions from the TEG Dehydrator Still Vent. As a
result, the total pilot gas fuel flow is 18.5 scf/hr.
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
Page 18 of 19
COLORADO
4441 Air Pollution Control Division
DPU
Department of Public Health&Environment
Dedicated to protecting and improving the heath and environment or the people of Colorado
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: NOx, VOC, CO, Benzene, Toluene,
Xylenes, n-Hexane, and Total HAPs
PSD Synthetic Minor Source of: CO
NANSR Synthetic Minor Source of: VOC, NOx
MACT HH Area Source Requirements
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A- Subpart UUUU
NSPS Part 60, Appendixes Appendix A Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 19 of 19
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Lauraleigh Lakocy
Package#: 419750
Received Date: 5/18/2019
Review Start Date: 4/21/2020 *Package was previously in process with Timothy Sharp,but transferred to L.L.4/21/2020.
Section 01-Facility Information
Company Name: Bonanza Creek Energy Operating Coruna^y,L_C Quadrant Section Township Range
County AIRS ID: 123 SEl 19 5"i 52
Plant AIRS ID: 9513
Facility Name: Antelope Section 19 CarnpressorStation(COG„Cr427583) ) A, � r '
Physical
Address/Location:
County: Weld County
Type of Facility: Natural Gas Compressor Station ;'` -'
What industry segment?Oil&Natural Gas Production&Processing m "`
Is this facility located in a NAAQS non-attainment area? Yet
If yes,for what pollutant? Ozone(NCI(v 'OG)
Section 02-Emissions Units In Permit Application
Leave Blank-For Division Use Only
Permit#
AIRs Point#
Emissions (Leave blank unless Issuance Self Cert Engineering
(Leave blank unless APCD Emissions Source Type Equipment Name Action
Control? APCD has already # Required? Remarks
has already assigned)
assigned)
Requesting
controls
installed on
Punt loadout
001 Liquid Loading L-01 Yes 12WE1563 7 No Modification operations.
This point was.
not previously
included on this
permit and was
Permit initial covered by a
002 Condensate Tank CNDT Cl Yes 12WE1563 7'' Yes issuance GP01.
Updating to
include new
inlet gas
composition
Permit and remove
018 Dehydrator DENY-01 Yes 12WE1563 7 No Modification stripping gas 1 y
Section 03-Description of Project
This source is adding the condensate tanks to this facility-wide permit(from a GP01 permit),adding controls to the tank loading operations;and updating the
operating parameters and corresponding emissions for the dehydrator onsite.This is an existing facility.This facility is synthetic minor for NOx,VOC,CO,and HAPs
(Total,n-hexane,benzene,toluene,xylene).The permitted,controlled emissions at this facility are greater than 40 tpy VOC.
Sections 04,05&06-For Division Use Only
Section 04-Public Comment Requirements
Is Public Comment Required? Yes
If yes,why? Requesting Synthetic Minor Permit
Section 05-Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) 00000 ❑
Title V Operating Permits(OP) O O ® Q ❑ ❑ ❑ ❑✓
Non-Attainment New Source Review(NANSR) O
Is this stationary source a major source? tdo
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) ❑ ❑ ❑ ❑ ❑ O
Title V Operating Permits(OP) 00000 000
Non-Attainment New Source Review(NANSR) O ❑
Hydrocarbon Loadout Emissions Inventory
Section 01-Administrative Information
123 9813 C
Facility AIRS ID:
County Plant Point
Section 02-Equipment Description Details
Detailed Emissions Unit ���� : r
Description Eontlensate Load rte— �4.1 -' P�i ,r �`�
Emission Control Devicet5
Enclosed Combustion __Fete(5)Leed 4s 27 ECOsj, %z
Description: =
ilia a
Is this loadout controlled? .. '+s.a^
90
Requested Overall VOC&HAP Control Efficiency%: `4S
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Hydrocarbon Loadout
Actual Volume Loaded= 61320 Barrels(bbl)per year
'Requested Permit Limit Throughput= 161,320_Barrels(bbl)per year Requested Monthly Throughput= >.__8 Barrels(bbl(per month
Potential to Emit(PTE)Volume Loaded= 01,323 Barrels(bbl(per year
Secondary Emissions-Combustion Devices}
Heat content of waste gas= ,^0°356,1?Btu/sef
Actual Volume of waste gas emitted per year= _sef/year
Requested Volume of waste gas emitted per year= 0 sef/Year
Actual heat content of waste gas routed to combustion device= MMBTU per year
Requested heat content of waste gas routed to combustion device= MMBTU per year
Potential to Emit(PTE)heat content of waste gas routed to combustion device= MMBTU per year M iffigiTERELUISIMIESILLO . f
," � uW G ,,
tiiktdadargAtiriagrAgEgeaSihndiegiffira.. xL
Section 04-Emissions Factors&Methodologies
Does the company use the state default emissions factors to estimate emissions?
Does the hydrocarbon liquid loading operation utilize submerged fill?
Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility
being permitted? -.v1.
Loading Loss Equation
L=12.46*S*P•M/T
Factor Meaning Value Units Source
9 Saturation Factor diniSIMSM. :P42S s .T$aahf>0.2-1 Suhmyvge OiciV4a₹aga edicated rdoifmzt .$w�V.0)
P True Vapor Pressure 6.78 psis AP-42,Chapter 7,Equation 1-24(R o.zlt's Lew/Antoine's Egos an)
M Molecular Weight of Vapors 62.77 lb/lb-mol AP-42,Chapter 7 Equation 1-23
T Liquid Temperature 523.67 Rankine Operating'ondi''-sn
Loading Losses _-lb/1000 gallons Loading Less.Equation
lb/bbl Loading Loss considerine98.7712 Vapor VOC Content
Component Mass Fraction Emission Factor Units Source
Benzene 9 9=904,00323 -2 Ib/bbl
Toluene 0.0013 lb/bbl
Ethylbenzene 0.00.,'7S [Ib/bbl Site-50,163 v e, , ton taker 7/122015-Weight 22 of TUC ch,7.15 __ion 1-23.
Xylene 0.Pe., lb/bbl See notes hel.,s
n-Hexane 0.0' lb/bbl
224 TMP 0 0 lb/bbl
Hydrocarbon Loadout
Uncontrolled Controlled
Pollutant (MAN) (Ih/bbl) Emission Factor Source
(Volume
(Volume Loaded) Loaded)
45943.,11439,"„._y`i
®s
MMMZEZM ®4
Control Device
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source
Volume
(waste heat combusted) Loaded)
® `
_®'
iummissmosimaittittrk-ifl'4.14V161.0-:
r;.31cc
ate Atmoogrffloggg � �,igI ;,
r. g " ash i
mksqgoworseipmg�e„ _ t. BEM. - .
�.. I R S ii.
EMENCEEIEVIEttalNINEINIMACIMISPAiiiiiffiRaginigiannanigUrai
2 of 10 C:\Users\Ilakocy\Desktop\Remote Working Dom\Package 419750\12W E1563.CP7.LL
Hydrocarbon Lioad'uut Emissions InverItoty
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) (Ibs/month)
PM10 Odd 0.00 ,.:,.
PM2.5 0.00 0.50 0 c!'. _-. 0
sox 0.00 3 0B _ 023, ..
NOx 0.00 as ....s., _
VOC 7.53 ..5 0.39
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (lbs/year) (lbs/year) Ohs/year) (lbs/year)
Benzene ., 2 =iS 2
Toluene 20 .. 1 - 20
Ethylbenzene - _
Xylene 2. .. 2
n-Hexane s._ 696 55
224TMP 0 3
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,B Source,n5':,' a ,23-
RACT-Regulation 3,Part B,Section lll.D,2.a he loadout must be operate.with submerged fill to satlaer RAC-3.
(See regulatory applicability worksheet for detailed analysis)
Section 07-Initial and Periodic Sampling and Testing Requirements
fiit
Does the company request a control device efficiency greater than 95%for a flare or combustion device? >nai•sa.;, ;.
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
The emissions factors are being modified slightly from the previous permit issuance.The emissions factors reflected in the permit match those requested by the source-there are slight differences which can be attributed to differences in rounding.
The loadout operations are controlled using a vapor balance that connects the truck vapor headspace to the storage tanks,and the displaced vapors are controlled along with the storage tank vapors.Therefore,there are no pilot light combustion emissions
associated with this point,as they are accounted for with the condensate storage tanks(point 002).
Vapor Composition(Mole%) Constituent NP,psia)*(Consituent Mole Fraction in Stable Oil)/(Total Liquid NP,psia)
Vapor Composition(Wt%)=(Constituent Mole Fraction)*(Consituent MW,lb/lb-mole)/(Total Vapor MW,lb/lb-mole)
See"Truck Loading Vapor Pressure and Speciation"calculation sheet received June 2,2020.
The gas HHV was estimated using the vapor compositions as calculated by AP.42.
Section 09-Inventory 5CC Codirm and Emissions Factors
Uncontrolled
Emissions
AIRS Point# Process tt 5CC Code Pollutant Factor Control% Units
0 01 50.000-22 Crude ON:sutznergod Loading^sor tool Sere 00 i5 C Vj PM10 0.00 0 kb/1,000 gallons transferred
PM2.5 .-.0,. 0 lb/1,000 gallons transferred
SOx 0.00 0 lb/1,000 gallons transferred
NOx .-._-, 0 Ib/1,000 gallons transferred
VOC vc 95 lb/1,000 gallons transferred
CO -_ lb/1,000 gallons transferred
Benzene .,.5. 95 lb/1,000 gallons transferred
Toluene ,-__ 95 lb/1,000 gallons transferred
Ethylbenzene 0.25 95 lb/1,000 gallons transferred
xylene 02 55 Ili/1,000 gallons transferred
n-Hexane 0.2' 95 lb/1,000 gallons transferred
224 TMP a se 95 lb/1,000 gallons transferred
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Hydrocarbon Loadout Regulatory Analysis Worksheet
The regulatory requirements below ore determined based on requested emissions.
Colorado Regulation 3 Parts A and B-APEN and Permit Requirements
Thirty is in die Non-A is=nr=ent Area
ATTAINMENT •
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section I1.0.1.a)?
2. Is the loadout located at an exploration and production site(e.g.,well pad((Regulation 3,Part B,Section 11.0.1.11?
3. Is the loadout operation loading less than 10,000 gallons(238 BBLs)of crude oil per day on an annual average basis? �llGi
4. is the loadout operation boding less than 6,750 bbls per year of condensate via splash fill? r= &
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 11.0.31? 1e,ri
you have Indicated that sours is:n the Non.Arroinm:nit hide
NON-ATTAINMENT
1.•Are uncontrolled emissions from any criteria pollutants from this ndry dual source greater than 1TPY(Regulation 3,Part A,Section ll.0.1.a1? tip$,.:; „Go to next
2. Is the loadout located at en exploration and production site(e.g.,well pad((Regulation 3,Part B,Section 11.0.1.1)7 hdb"a'h "..Go to the n
3. Is the loadout operation loading less than 10,000 gallons(238 BBLs)of crude oil per day on an annual average basis? f11311O't11LL Go to next
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? Nom:" Go to next
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? No Go to next
6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than 10 SPY(Regulation 3,Part 0,Section 11.0.21? e The loadou
'So: requires s parnis
7. RACr-Are uncontrolled VOC emissions from the loadout operation greater than 20 spy(Regulation 3,Part B,Section lll.D.2.a)? No• 'The loadou
IThe loadout mast bs operated with submerged fig to saris^.;YACT,
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 toe particular situation based upon the individual facts end 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 Qualify Contra(Commission regulations,but this document does not establish legally binding requirements in and of itself.
Condensate Storage Tank(s)Emissions inventory
•
Section 01-Administrative Information
(Facility AIRs ID: 123 .0813. 002
County Plant Point
Section 02-Equipment Description Details •
Detailed Emissions Unit One(1)300-bbl and two(2).00-551 fixed roof vessels usedt store condensate 'F' 'T-
Description:
Emission Control Device
Enclosed Combustion Device#Five it)Leed 48"ECDs) ��7y
Description: " ,.�. ... '. cn - .: z. F _
Requested Overall VOC&HAP Control Efficiency%: 95.0 $
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Storage Tank(s)
Actual Condensate Throughput= 51,100:0.Barrels(bbl)per year
Requested Permit Limit Throughput= 60,320,0 Barrels(bbl)per year Requested Monthly Throughput= . 3218.0 Barrels(bbl)per month
Potential to Emit(PTE)Condensate
Throughput= 61,320.0 Barrels(bbl)per year
Secondary Emissions-Combustion Device(s)
Heat content of waste gas= 262:3.0 Btu/scf From ProMax submitted April 2,2019:Total Tank Emissions Gross ideal Heating Value
Volume of waste gas emitted per BBL of liquids From ProMax submitted April 2,2019:Total Tank Emissions
produced= 97,B scf/bb.l Stream(0.0136655 MMSCFD),Flashed Liquid:4.08333 sgpm
Actual heat content of waste gas routed to combustion device= i3,0E9.t MMBTU per year
Requested heat content of waste gas routed to combustion device= 15.701.0 MMBTU per year
Potential to Emit(PTE)heat content of waste gas routed to combustion device= 15,7))5 9 MMBTU per year
Control Device
Pilot Fuel Use Rate: 92.5 scfh '.81 MMscf/yr
Pilot Fuel Gas Heating Value: 2624.Btu/scf 25.26.2 MMBTU/yr
Section 04-Emissions Factors&Methodologies
Will this storage tank emit flash emissions?
Emission Factors Condensate Tank
Uncontrolled Controlled
Pollutant (Ih/bbl) (lb/bbl) Emission Factor Source
(Condensate (Condensate
Throughput) Throughput)
VOC 9.9300
Benzene O.0350
Toluene .0.0170
Ethylbenzene 0.0010 _
Xylene 0.0020 _ Ec(iV ..
n-Hexane 0.3060 +. 1 &0pe f.'EOM
224 IMP 0,0010 _CCo.", Speuitc F.
Control Device
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source
(waste heat (Condensate
combusted) Throughput)
PM10 7,7712 •t (
PM2.5 00075 r,7,77,24,90,97:
NOx 0.0680
CO 0.3100 -4`al Pate,(Co,
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (Ib/MMscf) Emission Factor Source
(Waste Heat (Pilot Gas
Combusted) Throughput)
PM10 0.0075 ;3 2Si
PM2.5 0.0075 19.5574
NOx 0.0680 178.4370
CO 0.3100 813.2210 ... ..... ',`- _.
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 304.5 253.7 -- 3,-,_ 15.2 2.300.0
PM10 0.1 0.1 _._ _._ 0.'1 11.3
PM2.5 0.1 3,1 0.1 _... O./ 11.3
NOx 0.6 0.5 0 5 1,y 0.6 103.0 •
CO 2.8 2.4 _. 2.8 2.8 469.5
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (lks/year) (Ibs/year) (Ibs/year) (Ibs/year)
Benzene 2146.2 1783.5 39.4 2141.2 107.3
Toluene 101.2.4 860.7 43.4 16'15.== 52.1
Ethylbenzene 61.1 51.1 2.6 3,.3 3.1
Xylene 122.6 107.2 5.1 172.0 6.1
n-Hexane Ir 18763.6 15535.6 781.8 17703.0 938.2
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Condensate Storage Tank(s)Emissions inventory
224TMP I I I 2.6 I =i.3 I 3,1 I
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Condensate Storage Tank(s)Emissions inventory
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,B perm
Regulation 7,Section XII.C,D,E,F __. subject to Regulation 7,Section Xli.C
Regulation 7,Section XII.G,C not scbj=ct to Regulation 7.Section Xn.O
Regulation 7,Section XVII.B,C.1,C.3 ..suhjecrto Regulation Section XVIi,R,CT&%.3
Regulation 7,Section XVII.C.2 objecttmRegulation;',Section XVlLC2
Regulation 6,Part A,NSPS Subpart Kb age not subject to NSPS Kb
Regulation 6,Part A,NSPS Subpart 0000 Storage Tana is not subject to HOPS 0000
NSPS Subpart 0000a Storage tanx:is not sufoect to NSPS 00000.
Regulation 8,Part E,MACT Subpart HH .Sro,a=e Tank is not subject to MACT 5H
(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? 37
If yes,are the uncontrolled actwal 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 them 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 ,ax,
collected within one year of the application received date.However,if the facility has not been modified(e.g.,no -•zT�
new wells brought on-line),then it may be appropriate to use an older site-specific sample. a 3 r%
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.
z�u
Does the company request a control device efficiency greater than 95%for a flare or combustion device? a
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
Source is requesting traditional permit coyeragefor.this;point which wag/previously permitted under the G P01.The source is requesting to use previously approved emissions f actors,based on the APEN
w -
received April,2019 These emission factors Were cal olated based on a pressurized liquid sample analysis take 2/15/2019 wth a pressure of 67.9 psig and temperature of 70 deg F.
VOC Pilot light combustion emissions calculation(per AP-42,Table 1.4-2):5.5 lb/MMscf/1020 btu/scf c 1930.8 MMBTU/yr=10.4 lb/year
The CO permitted limit reflects a slighter higher value than that calculated above due to minor roundingdifferences.Thepennit reflects the more conservative value as requested by the source.
Source used 500 bbl tank size to estimate w/b emissions-see stencil recieved 6/2/2020.This Is anticipated to bee conservative estimation of w/b emissions for this tank battery.
Per email receieved 6/2/2020,the source does not agree with the NSPS Kb determination as the facility:is still within the"rroducing operations"and asserts that if the facility is subject to NSPS Kb,then
they are categorically exempt from NIPS 0000/0000a requirements.This source is not subject to NIPS 0000 requirements as a storage vessel affected facility.This source may be subject to NSPS
0000 as a"reciprocating compressor affected facility". `-
Section 09-Inventory SCC Coding and Emissions Factors
Uncontrolled
Emissions
AIRS Point# Process# SCC Code •Pollutant Factor Control% Units
01 "' „.' ;u Yt ` ." " i, i;"' PM10 0.05 0 lb/1,000 gallons condensate throughput
PM2.5 0.05 0 lb/1,000 gallons condensate throughput
NOx 0.47 0 . lb/1,000 gallons condensate throughput
VOC 236.4 95 Ib/1,000 gallons condensate throughput
CO 2.15 0 lb/1,000 gallons condensate throughput
Benzene 0.83 - 95 lb/1,000 gallons condensate throughput
Toluene 0.40 95 lb/1,000 gallons condensate throughput
Ethylbenzene 0.02 95 lb/1,000 gallons condensate throughput
Xylene 0.00 95 lb/1,000 gallons condensate throughput
n-Hexane 7.29 95 lb/1,000 gallons condensate throughput
224 TMP 0.02 95 lb/1,000 gallons condensate throughput
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Source: ProMax Simulation submitted April 2, 2019 (with previous GP01 appl)
Based on: Site-specific pressurized liquid sample collected 2/15/2019
Mass Flow (lb/Hr)
Compound Total Tank Emission Factor Total
of VOC
(lb/bbl) EF(W/B/Flash)
Emissions Stream
H2S 0.000000
Nitrogen 0.068435 0.011732
CO2 0.671740000 0.115156
CH4 3.26026 0.558902
Ethane 8.2322 1.411229
Propane 17.7286 3.039191
Isobutane 4.3347 0.743095 7.556
Butane 14.8561 2.546762 25.896
Isopentane 5.55912 0.952993 9.690
Pentane 7.6133 1.305133 13.271
Cyclopentane 0.570201 0.097749 0.994
n-Hexane 1.78585 0.306146 3.113 0.306146
Cyclohexane 0.40632 0.069655 0.708
Methylcyclohexane 3.78556 0.648954 6.599
Heptane 0.22911 0.039277 0.399
2,2,4-Trimethylpentane 0.0049337 0.000846 0.009 0.000846
Benzene 0.202770 0.034761 0.353 0.034761
Toluene 0.100898 0.017297 0.176 0.017297
Ethylbenzene 0.0057629 0.000988 0.010 0.000988
m-xylene 0.011538 0.001978 0.020 0.001978
Octane 0.15150 0.025972 0.264
Nonane 0.022594 0.003873 0.039
Decanes+ 0.000003 0.000000 0.000
VOC's 57.36885643 9.835 9.835
Hours/Year 8760
Throughput(bbl/yr) 51099.95829
i
b b #pry
�� � 4 '.! ..S
. .„- ., ✓) it,.. %",4-W
Condensate Tank Regulatory Analysis Worksheet
The regulotory requirements below are determined based on requested emissions.
Colorado Re tau 3 P Aand B PE nd Permit Requirements
Colorado
�
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section ll.D.1.a/?
2 the tru date(service date)prior to 12/30/2002 and not modified after 12/31/2002(See PS Memo 05.01 Definitions 1.12 and114 and Section 2 for additional guidance on grandfather appllcabllky)?
3 Are total fcility uncontrolled VOC emissions greater than STPY NOx greater than SO TPY or CO emissions greater than lO TPY(Regulation 3,Part 0,Secton IID3I?
iivricxx.,,hat source un-rte. ....true..
NON-ATTAINMENT
1. Are uncontrolled emissionsfrom anyaneria pollutantsfrom this individual source greater than 1 TPY(Regulation 3,Part A,Section ll.D.l.a)? Yes.-"':"€a;.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 aed1.14 and Section 2 for additional guidance on grandfather applicability)? ftftla11114.ti Go to next question
3. Pretotal facility uneontrailed VOC emissions greater than 2TPY,505 greater than 5TPY or CO emissions greater than 30 TPY(Regulation 3,Part 8,Section 0.1.2)7 :fgta./IS/'Source Requires a permit
Colorado Regulation J.5ectign Xli.C-F
1. Isthb storage tank located In the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance areal es Continue-You have indicatedth
2. Is this storagetank located at an oil and gas exploration and production operation',natural gas compressor station Or natural gas drip station? Ye, Continue-You have indicated th
3 Is the storages ate ups natural processing pant?
tank d t f l l
YbsP-30A Source issublect
Section%%C.1—General Requirements for Air Pollution Control Equipment—Prevention of Leakage
Section XII.C.2—Emission Estimation Procedures
Section MIA/—Emissions Control Requirements
Section ALE—Monitoring
Section KII,F—Recgrdkeeping 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? f eh 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 the storage tank exhibit'Fl h(e.g.storingnon-stabilized lquids)emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC? fag, w Source is subject
Section XII.G.2-Emissions Control Requirements -
Section Xll.C.1—General Requirements for Air Pollution Control Equipment—Prevention of leakage
Section tet.C.2—Emission Estimation Procedures
Colorado Regulation],Section%VII
1. Is thb tank located at a transmission/storagefacility? Continue-You have indicatedth
2. Is this condensate storage tanks located at an ail and gas exploration and production operation,well production facility',natural gas compressor station'or natural gas processing plant? Go to the next question-You ha
3. Is thb condensatestoragetank a fixed roof storagetank? .-s. Go to the next question
4. Are uncontrolled actual emissions of this storage tank equal to or greater than 6 tons per year VOC? Vr3, Source is subject to parts of Reg:
Is? - ,a R00u!aftoo 7.Sp.on X,./,Is,C.1.4
Section 10/II5 cGeneral Provisions for Alr Pollution Control Equipment and Prevention of Emissions
Section IMI.C.1-Emissions Control and Monitoring Provisions
Section KVII.C.3-Recgrdkeeping Requirements
5 Does the condensate torage tank contain only"stabilized"Squids? I Ivr, Sources subject to all
j provision:
Section%VII.C.2-Capture and Monitoring for Storage Tanks fined with Ail-Pollution Control Equipment
40 CFR.Part 60.Subvert Kb.Standards of Performance for Volatile Ornnic Liquid Storage Vessels
I. Is the individual storage vessel capacity greaterthan or equal to 75 cubic meters(m')(-472 B01s]? Go to the next question
2. Does the storage vessel meet the following exemption in 60.1llb(d)(4)? 'I,, Go to the next question
a.Does the vessel has a design capacity less than or equal to 1589.8740[-10,OW BBL]used far petroleum.or condensate stored,processed,or treated prior to custody transfer'as defined In 60.011k?
3. Was this condensate storage tank constructed,reconstructed,or modified(see definitions 40 CFR,60.2)after July 23,1984? Go to the next question
4. Does the tank meet the definition of"storage vessel'in 6D.111b? ®Go to the next question
5. Does the storage vessel store a"volatile organicliquid(VOL)"'as defined:in 60.1116? Go to the next question
S. Does the storage vessel meet any one of the following additional exemptions: ®Storage Tank is not subject NSPS
a.Is the storage vessel a pressure vessel designed to operate in excess of204.9 kPa[-29.7psi]and without emissions tothe atmosphere(60.110b(d)(2))?;or "5-1.W4
b.The design capacity is greater than or equal to 151 m'['950 BBL]and stores a Squid with a maxmumtrue vapor pressure'less than 3.5 kPe(60.1106(61)1;or .�ES.
c.The design capacity is greater than or equal to 75 M'(-472 BBL)but less than 151 m'['950 BBL]and stores a liquid with a maximum true vapor pressures less than 15.0 kPa(60.1105(b))? f
7. Does thestoragetank meet either one of the following exemptions from control requirements:
a.The design capacity is greater than or equalio 151 m'[`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 Mt[-472 BBL]but less than 151 m'[-950 BBL]and stores a Squid with a maximum true vapor pressure greater than or equalto 15.0 We but less than 27.6 kPa?
40 CFR,Part 60,Subpart 0000/0000a,Standards of Performance for Crude Oil and Natural Gas Production,Tmnsmislan end 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? - Continue-You have indicatedth
2. Wasthis condensate storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)between August 23,2011 and September 18,2015? -Gotothequetion 4.
3. Wasthis condensate storage vessel constructed,reconstructed,or modified(see definitions 40CFR,60.2)after September 18,2015?
4. Are potential VOC emissions'from the individual storage vessel greater than or equal to 6 tons per year? tie Storage Tank is not subject NSPS
5. Does thb condensate storage vessel meet the definition of"storage v ssel'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 or40 CFR Part 63 Subpart HA? NA:
'Store.,_Tank t:rrt spolc.lro NSPS„
[Note:If a storage vessel is previously determined to be sulliectta NIPS 0000/0000a duets emissions above 6 tons per year VOC onthe applicability determination date,it should remain subject to NSPS 0000/0000a per
eo.5365(e)(2]/6a.5365a(e)(2)even if potential l/OE emissions drop below 6 tons per year]
40 CFR.Part 63.Subpart MALT HH.Oil and Gas Production Facilities
1. Is the storage tank located at an oil and natural gas productianfacllky that meets either of the following criteria: Irmo 'Continue-You have indicated th
a.A facility that processes,upgrades or stores hydrocarbon liquids'(63.76o(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 D delivered to a final end user'(63.760(a)(3)I7
2. Is the tank located at a facility that is major'for HAPs? Ne. Storage Tank is not subject MAC
3. Does the tank meetthe definition of"storage vessel"'in 63.761? ryj
4. Does the tank meet the definition of"storage vessel with the potential for flash emissions"'per 63.761?
5. h tanksubject to control requirements der40 CFR Part 60,Subpart Kb or Subpart 0000? -VA
Subpart A,General provisions per§63.764(a)Table 2
§63.766-Emissions Control Standards
§63.773-Monitoring
§63.]74-Recgrdkeeping
553.775-Reporting
RAC?Review
PACT review Is required if Regulation 7 does not apply AND it the tank Is In the non-attainment area.If the tank meets both criteria,then review RACE requirements.
Disclaimer
This document assists opera/ors with determining applicability of certain requirements al the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is
not a rule or regulation,end the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances.This document does not change ar substitute for any law, •
regulation,or any other legally binding requirement end is not legally enforceable.In the event ofany conflict between the language of this document and the language of the Clean Air Act„its implementing
regulations,and Air Qualify Control Commission regulations,the language of the statute or regulation Pill control.The use of non-mandatory language such as'recommend,""may,"'should,"and"can."is
intended to describe APCD interpretations and recommendations.Mandatory teminology such as"must"and"required"are intended to describe controlling requirements under the terms Mitre Clean Air
Act and Air Qualify Control Commission regulations,but this document does not establish legally binding requirements in end outsell
Glycol Dehydrator Emissions Inventory
Section US-Administrative Information
123.- a8t3,
'Facility AIRS ID: County Plant Point
Section 02-Equipment Description Details
Dehydrator Information
Dehydrator Type: „,
Make: r;6J ifibssn.:.`. rdsg:.
Model: HA
Serial Number:
Design Capacity: 3P MMscf/day
Recirculation Pump Information
Number of Pumps _ S
Pump Type
Make: t4Smt.5g'.
Model:
Design/Max Recirculation Rate: Vs gallons/minute
Dehydrator Equipment
Flash Tank ,flash tank,
Reboler Burner +;=a. and reboil er burner
Stripping Gas - -
Dehydrator Equipment Description
Emission Control Device Description: .... -
Section 03-Processing Rate Information for Emissions Estimates
Printery Emissions-Dehydrator Still Vent and Flash Tank(it present)
(Requested Permit Limit Throughput= Stoma,?, MMscf per year Requested Monthly Throughput= MMscf per month
Potential to Emit(PTE)Throughput= -..?5.l MMscf per year
Secondary Emissions-Combustion Device(s)for Air Pollution Control
Still Vent Control Dry Gas Throughout:
Condenser: Still Vent Primary Control' ''MMscf/yr MMscf/month
Condenser emission reduction claimed: Requested Condenser Outlet Temperature: Degrees F Still Vent Secondary Control -MMscf/yr
Primary control device: 83e Control Efficiency% Waste Gas C mbusted,
Primary control device operation: Q?LV hr/yr Requested TO Temp N/A y Degrees F Still Vent Primary Control: I __MMscf/yr MMscf/month
Secondary control device: A'',#&"≥ , Control Efficlenor Still Vent Secondary Control -^MMscf/yr
Secondary control device operation: hr/yr
Still Vent Gas Heating Value: BOQ,Btu/scf
Still Vent Waste Gas Vent Rate: SAMOA sclh
Flash tank Control Dry Gas Throughput:
Primary control device: _yV ' 100%Control Efficiency% Flash Tank Primary Control: ...a_....J MMscf/yr
Primary control device operation: AVbdt hr/yr FlashTank Secondary Control: MMscf/yr
Secondary control device ;, Control Efficiency% Waste Gas Combusted:
Secondary control device operator: hr/yr Flash Tank Primary Control: C'MMscf/Yr
Flash Tank Gas Heating Value Btu/scf Flash Tank Secondary Control: MMsct/yr
Flash Tank Waste Gas Vent Rate: ecth
Primary Control Device I Secondary Control Device I4 '
Plot Fuel Use Rate: ₹-ytty scth MMsct/yr Pilot Fuel Use Rate: ccfh MMscf/yr
Pilot Fuel Gas Heating Value: 5543 Btu/scf Pilot Fuel Gas Heating Value: Btu/scf
Section 04-Emissions Factors&Methodologies
Dehydrator
U£tO-G1.YCAkg Vyu i—u4,?
gayer)eharelent,wetyyyScv ic£zkrs'00,19,Thtsah,,pr;evsastar, taDcgFand11AVpsiywiriiethyrsadeticputioas tVOdeypoodityigt 't'ha
3aelgs ievaitodc i(sant000 „=: ca^r'utronss ,d(e wvcivilru trratth.*setupe rurejyrosure5rOdelcdyiuldoita muesanservottcycyyhnathuoott
Input Parameters
Inlet Gas Pressure E#1U prig
Inlet Gas Temperature '3g5J-. deg F
Requested Glycol Recirculate Rate P.S gpm
Control Scenario
STILL VENT Primary Secondary
Pollutant Uncontrolled(Ih/hr) Controlled(lb/hr) Controlled(lb/hr)
VOC
Benzene
Toluene -.
Ethylberoons 1.10,
Xylen s
n-Hexane Q 4'524 :.
224-TMP
Control Scenario
FLASH TANK Primary Secondary
Pollutant Uncontrolled(lb/hr) Controlled(lb/hr) Controlled(Ib/hr)
Voc •5D.saa»
Benzene
is
Toluene ,� ¢� .,
Ethylbenzene -
XYlenes A
n Hexane -So -
224-TMP
Glycol Dehydrator Emissions Inventory
Emission Factors Glycol Dehydrator
Uncontrolled Controlled
Pollutant (Ib/MMscf) (Ib/MMscf) Emission Factor Source
(Dry Gas Throughput) (Dry Gas Throughput)
VOC ®® 1
Beraene
Toluene gail IME=MR,50;353MMPRWAVV"‘.54440•415,
Ethylbenzene -4,A ;;�h'
Xylene IIIMEMI
n-Herne
224 TMP ®®
IMEMEMEESISTMEMEEM
Uncontrolled Uncontrolled
Pollutant llb/MMBtu( (Ib/MMscf) Emission Factor Source
(Waste Heat (Waste Gas
Combusted( Combusted)
PM10
PM2.5 IIIEOMITEIIIIIII ;IiilititaAricit ,o„,„: -.0.1 .71:-414*."
SDz
NOx �®
CO
:P E _ �; x
MINMEMPIEIMBEECISSITRIMEMEMEEMINNSBAREMPE0PRI
"PEN ' 1
c: : ;a..,. ..{ _ oaf '1, .
b x
S.FEWAIR.v.. EE : E��P�vk.A.�_ ,u EX&£ ..,.�&. (ykygs�S T_"` �'E'' E 'r igg'A,5<5t...'?rkbf"�r
pper(��(./IX.KM� d.;w4.9M,r. dbIXM" Ry�k ff.BIWERNEELMEOLZIENENESMM;SOI IMIR(q�O• '#MEnal 4 ` %kµ R- `Y( .O•.L':
SgYkEE., .P"in' { fw. /,u b5ESzik".M' 'PINUR" '.x ..... . 4<a/;;3
m.
kitagni
r
�e ��tT. 6'� r Lgiiii&ANdifietaisliKagagp /s:. fYA Y�,': . 9 G
iiimEXPANIZONIEVIyg MINIONSPEZINEraliattittinglifethliftiwigAtaiRMANglipplatflintgagiiiitaliEllegq
IMEIVINNamgad
:;...,.,.n ,�.......ex iowiliftRaA g=ffdomoE ::......,E rz .:1.
pram r:_..goolyesamamtellegAnamsevi� a;i�isa "- , .. M 7r E :s;u' B EY riE^,.,<--vmmo j
m x : x� .m .,,asp mm. :iorwalompailogg .. - y dt"'
VailitiaitititerillifferailliENNESEMACMOMBERIgiataideaRtiffandiagfiggl
Primary Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu( (Ib/MMscf) Emission Factor Source
(Waste Heat
Combusted( (Pilot Gas Throughput)
PM30 ®® ..4f 7-'''''
PM2.5
SOz
ROz mitzsam CO • ee.. x.r557 ...
I gl ..: ffalni"•,..5557,-..5'7,55;f:.":
'`w": ..,, i.:,.a • g.O{M '""i f�i7.C'7-`iBWIraMidgi �l
'� Via'.,. Z";;:bd'.tea'== <c:; r ,:�7yl9.4f,�s'
x :ty�•'r�rgn'
k:_IIwH a ppgrAgNoMAISORp. MIS
Section 05-Emissions Inventory
Did operator request a buffer? r
:'`
Requested Buffer(%): �7'
Requested Monthly
Craeda.Pollueanis Potential to Emit Actual Emissions Requested Permit Limits Limits
Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tons/year) (tons/year) (tons/year( (tons/year) (Ras/month)
PM10 _3 ,
PM2.5 ._ _.
500 __ 6, _.: .._ <,
CO __ 1.2 ..Z, ._.
HOC »34.3 .. <„,.5 o., _n.
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(Ibs/year( (Ibs/year( (Ibs/year( (Ibs/year( (Ibs/year)
Benzene - _ WOOL =3182 1887
Toluene - .,,7_ ?357
Ethylbenzene _.. - - - 375
Xylene - 2318
n-Henna - - 243
224 TMP - _ - D •
Section 04-Reeulatary Summary Analysis
Regulatlon 3,Parts A,B
Regulation 7,Section X811.0,5 .0:r c<.,__. _ ' e::7,Section XVil,8,7.3
Regulation 7,Section XVII.B.2.e
Regulation 7,Section Xll.H - 7,Section Xll.H
Regulation B,Part E,MACT Subpart HH(Area( - - - -Yemptlan
Regulation B,Part E,MACT Subpart HH(Major( - - not subject to Major Source rcquirernenls ai MACT Hi.
Regulation B,Part E,MACT Subpart HHH - - ,.is not aubjatl to MACT t<ily.
(See regulatory applicability worksheet for detailed analysis(
Glycol Dehydrator Emissions Inventory
Section 07-Initial and Periodic Sampling and Testing Requirements
Was the extended wet gas sample used in the GlyCalc model/Process model site-specific and collected within a year of
application submittal?
If no,the permit will contain an"Initial Compliance'testing requirement to demonstrate compliance with emission limits
Does the company request a control device efficiency greater than 95%for a flare or combustion device? `=.s'
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 '
If the company has requested a control device efficiency greater than 95%,is a thermal oxidizer or regenerative thermal oxidizer being used to achieve it?
if yes,the permit will contain en"Initial Compliance"stack testing requirement AND the permit will contain a condition specifying the minimum combustion chamber temperature for the thermal oxidizer based on the
O&M plan and application.Once a stack test is approved by the division,the minimum combustion chamber temperature will be based on the most recent stack test results.
Is the company using a thermal oxidizer AND requesting a minimum combustion chembertemperature lower than 1,400 degrees F?
If yes,the permit will contain an"Initial Compliance"testing requirement AND a permit condition specifying the minimum combustion chamber temperature for the thermal eddiaer
based on the O&M plan and application.Once a stack test is approved by the division,the minimum combustion chamber temperature wllkbe based en the most recent stack test
resuts.
Section08 Technical Analysis Notes
The HAP 0-vesions in the Notes to.errr..-ryruer march the values._q,s.7t<_e-hthe source There nitre,riy.err m.or dfrer ences, differences
Section 09-Inventory 5CC Coding and Emissions Factors
Uncontrolled
AIRS Point# -Process# SCC Cade Pollutant Emissions Factor Control% Units
01 to PM10 2.00? 0.a b/MMscf
PM2.5 0005 0.0 b/MMscf
500 0000 10 b/MMscf
NOx _.04'4 - b/MMsct
VOC 75.8 i_.. b/MMscf
CO 3.213 c.0 b/MMscf
Benzene ay05 :._ b/MMscf
Toluene 0.430 i_ b/MMsct
Ethylbenzene 1.056 955.1 b/MMscf
Xylene 4.250 55.1 b/MMscf
n-Hexane :.055. 07.3 b/MMscf
224 TMP acme ehhilCl b/MMscf
Dehydrator Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and B-APEN and Permit Requirements
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.3)?
�Ys:+ra have inddta'ted that Mtniitne i:,in the No,Attr.o-rarnes'rt Area
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY(Regulation 3,Part A,Section II.D.1.a)? ;;„:.. ,
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section I I.D.2)?
'Source requires a pee'mit
Colorado Regulation 7,Section XII.H
1. Is this glycol natural gas dehydrator located in the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area(Reg 7,Section XII.H.1 and 2)? Yes
2. Is this glycol natural gas dehydrator located at an oil and gas exploration and production operation',natural gas compressor station,natural gas drip station or gas-processing plant(Reg 7 Section Yeti
3. Is the sum of actual uncontrolled emissions of VOC from any single dehydrator or group of dehydrators at a single stationary source equal to or greater than 15 tpy(Reg 7,Section XII.H.3.b)?
4. Are actual uncontrolled emissions of VOC from the individual glycol natural gas dehydrator equal to or greater than 1 tpy(Reg 7,Section XII.H.3,a)? T.
Dehydrator is subject to Rlegulation 7,Section XlI.Il
Section XII.H—Emission Reductions from glycol natural gas dehydrators
MACT Analysis
1. Is the dehydrator located at an oil and natural gas production facility that meets either of the following criteria:
a.A facility that processes,upgrades or stores hydrocarbon liquids'(63.760)a((2));OR
A facility that processes,upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end
b, user'(63.760(a)(3))?
• 2. Is the dehydrator located at a facility that is a major source for HAPs? gci,v,engi
IA.to MAGI'' -I A r Ro7Jdrlacor.ri,.r::t€tan to deter imne MAC I I III sppl@cataility
40 CFR,Part 63,Subpart MACT FIN,Oil and Gas Production Facilities
Area Source Requirements
•
1. Is the dehydrator a triethylene glycol(TEG)dehydration unit(63.760(b)(2))?
Exemptions
2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3,001747 MMscf per day(63.764(e)(1)(i)? 14110.401'
2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr(63,764(e)(1)(ii)? %C"" xj"'
3. Is the unit located inside of a UA plus offset and UC boundary area?
I The daby unfit meets the benzene srxs'caption
Subpart A,General provisions per§63.764(a)Table 2
§63.765-Emissions Control Standards Do Not Apply
§63.773-Monitoring Standards Do Not Apply
§63.774-Recordkeeping
§63.775-Reporting Standards Do Not Apply
Major Source Requirements
Does the facility have a facility-wide actual annual average natural gas throughput less than 0.65 MMscf/day AND a facility-wide actual annual average hydrocarbon liquid throughput less than 249.7
1. bbl/d(63.760(e)(2))?
Small or Large Dehv Determination
2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day(63.761)?
2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr(63.761)?
Small Dehv Reopjrernents
3. Did construction of the small glycol dehydration unit commence on or before August 23,2011(63.760(b)(1)(i)(B)and(C)?
4. For this small dehy,is a control device required to meet the BTEX emission limit given by the applicable equation?
I no Trove indicated that this facility is not subject to Mayo Source.toquiremorry,of MOOT I-il-I.
Subpart A,General provisions per§63.764(a)Table 2
§63.765-Emissions Control Standards
§63.773-Monitoring
§63.774-Recordkeeping
§63.775-Reporting
40 CFR,Part 63,Subpart MACT HHH,Natural Gas Transmission and Storage Facilities
1 Is the facility wide actual annual average natural gas throughput less than 0.9994051 MMscf/day and glycol dehydrators the only HAP emission source(63.1270(f))?
Small or Large Dehv Determination
2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 9.994051 MMscf per day(63.1270(b)(2)(?
2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr(63.1270(b)(2))?
Small Dehv Requirements
3. Did construction of the small glycol dehydration unit commence on or before August 23,2011(63.1270(6)(2)and(3))?
4. For this small dehy,is a control device required to meet the BTEX emission limit given by the applicable equation?
'You have indicated that.this lac city is not sutloct_tra MAL i sitlh.
Subpart A,General provisions per§63.1274(a)Table 2
§63.1275-Emissions Control Standards
§63.1281-Control Equipment Standards
§63.1283-Inspection and Monitoring
§63.1284-Recordkeeping
§63.1285-Reporting
Colorado.Regulation 7,Section XVII.D
1. Is the dehydrator subject to an emissions control requirement under MACT HH or HHH(Regulation 7,Section XVII.B.5)? No
2. Is this dehydrator located at a transmission/storage facility? No
3. Is this dehydrator located at an oil and gas exploration and production operation,natural gas compressor station or gas processing plant(Reg 7,Section XVII.D.3)? Yes
4. Was this glycol natural gas dehydrator constructed before May 1,2015(Reg 7 Section XVII.D.4.b)?
If constructed prior to May 1,2015,are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to or greater than 6 tons per year VOC or 2 tpy VOC if the dehydrator ( �
4a. is located within 1,320 feet of a building unit or designated outside activity area(Reg 7,Section XVII.D.4.b)?
5. If constructed on or after May 1,2015,are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to or greater than 2 tpy VOC(Regulation 7,Section XVII.D.4.a)?
'Dehydrator it subject teaitegulation'7,Section XVii,Fa,0.:$
Section XVII.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.D.3-Emissions Reduction Provisions
Alternative Emissions Control(Optional Section)
6. Is this glycol natural gas dehydrator controlled by a back-up or alternate combustion device(i.e.,not the primary control device)that is not enclosed?
Thetc0nrroi device for this dtrlsydrater is net,subject to Regulation'7,Section XVILT'b.2;2
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
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name_ Bonanza Creek Energy Operating Company,LLC
County AIRS ID 123 History File Edit Date 7/1/2020
Plant AIRS ID 9813 Ozone Status Non-Attainment
Facility Name Antelope Section 19 Compressor Station Last Modified By: Lauraleigh Lakocy
EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year)
AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S 502 NOx VOC Fug CO Total REMARKS
VOC HAPs VOC HAPs
Previous FACILITY TOTAL 3.6 3.6 0.0 0.0 668.4 656.3 0.0 564.0 47.3 3.9 3.9 0.0 0.0 50.2 80.9 0.0 95.3 9.7 From September 2018
3.9 3.9 0.0 0.0 50.2 80.9 0.0 95.3 9.7
001 12WE1563 Condensate Truck Loadout 0.0 7.7 0.0 0.4 0.0 0.4 0.0 0.0 Added controls,update SSEFs
002 12WE1563 tctoiIUCIIJcaLC'aim.,t'-mow w.,C.A.A., 0.6 304.6 2.8 11.1 0.6 15.2 2.8 0.6 Convened to CA.updated ihrovuhput
003 GP02 CN Caterpillar G3304 NA HCR,1800 RPM - =Cancelled 2/13/13
004 GP02.CN Caterpillar - Cancelled 2/13/14
005 GP02.CN Caterpillar Cancelled 4/16/13
006 GP02.CN Caterpillar G342 NA HCR Cancelled 2/13/13
007 GP02.CN Caterpillar G342 NA LCR _ Cancelled 9/7/13
008 GP02.CN Cummins KTA19GC .- Cancelled 4/16/13
009 GP02.CN Caterpillar 670 hp Cancelled 06/19/2016
010 GP02.CN Caterpillar G3516B LE Cancelled 6/7/18
011 GP02.CN Caterpillar G3516B LE Cancelled 6/7/18
012 GP02.CN. Caterpillar 03516B LE Cancelled 1/17/17
013 . 12WE1563.CN Pneumatic Heat Trace Pump Cancelled 2/10/17
014 12WE1563.CN. Pneumatic Heat Trace Pump Cancelled 5/23/16 to combine w/013
015 12WE1563.CN Fugitive Emissions Cancelled 03/27/2015
016 GP02.CN RICE 1085 hp 0.0 0.0 Cancellation Rec'd 10/25/2018
017 GP02.CN RICE 1680 Hp Cancelled 8/9/18
018 12WE1563 TEG Dehydrator 0.3 0.3 0.3 436.80 1.2 79.1 0.3 0.3 0.3 8.50 1.2 3.7 Updating operating parameters&emissions
019 GP02 RICE-Waukesha 1068 hp 1.2 1.2 215.8 5.70 181.7 1.8 1.2 1.2 8.2 3.30 24.4 1.3
_ _
020 GP02 RICE-Waukesha 1068 hp 1.2 1.2 215.8 5.70 181.7 1.8 1.2 1.2 8.2 3.30 24.4 1.3
021 GP02 RICE-Waukesha 1068 hp 1.2 1.2 215.8 11.4 181.7- 1.6 1.2 1.2 11.4 11.4 24.4 1.6
APEN Exempt/Insignificant Sources
Produced Water Tank 1 0.9 0.1 0.9 0.1 From Form APCD-102 Rec'd 9/18/2019
Produced Water Vaults 0.3 0.0 0.3 0.0 From Form APCD-102 Rec'd 9/18/2019
Heated Separators 0.3 0.3 0.0 0.3 0.3 0.0 From Form APCD-102 Reed 9/18/2019
Fugitive Equipment Leaks 0.3 0.0 0.3 0.0 From Form APCD-102 Reed 9/18/2019
Pig Receiver 0.1 0.0 0.1 0.0 From Form APCD-102 Reed 9/18/2019
Compressor Blowdown 0.5 0.0 0.5 0,0 From Form APGP-142 Rec'd 9/19/2019
VOC: Syn Minor(NANSR and OP)
NOx: Syn Minor(NANSR and OP)
FACILITY TOTAL 3.9 3.9 0.0 0.0 648.6 773.7 0.3 549.4 96.0 3.9 3.9 0.0 0.0 29.0 43.9 0.3 77.5 8.6 CO: Syn Minor IPSO and OP)
HAPS: Syn Minor n-Hexane,Benzene Toluene,
• Xylene,&Total
Permitted Facility Total 3.9 3.9 0.0 0.0 648.3 771.9 0.0 549.1 95.8 3.9 3.9 0.0 0.0 28.7 42.1 0.0 _ 77.2 8.5 Excludes units exempt from permits/APENs
Pubcom required because new syn minor limit<50
(A)Change in Permitted Emissions 0.0 0.0 0.0 0.0 -21.5 -38.8 0.0 -18.1 -1.2 tpy VOC, modeling not required based on division
guidelines
1 Total VOC Facility Emissions(point and fugitive) 44.2 Facility is eligible for GP02 because<45 tpy
(A)Change in Total Permitted VOC emissions(point and fugitive) -38.8 Project emissions less than 25 tpy
Page 15 of 16 • Printed 7/16/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name Bonanza Creek Energy Operating Company,LLC
County AIRS ID 123
Plant AIRS ID 9813
Facility Name Antelope Section 19 Compressor Station
Emissions-uncontrolled(lbs per year
POINT PERMIT Description Formaldehyde Acetaldehyde Acrotein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224TMP T0TALIipy)
001 12WE1563 Condensate Truck Loadout 46 4 698 0.4
_
002 GP01 3-300 bbl condensate Storage 2132 1061 Cl 121 18773 C,2 11.1
003 GP02.CN Caterpillar
004 �GP02 CN Caterpillar .
005 GP02.CN . Caterpillar
006 GP02.CN Caterpillar G342 NA HCR
007 GP02.CN Caterpillar G342 NA LCR
008 GP02.CN Cummins KTAI9GC
009 GP02.CN Caterpillar 670 hp _
010 GP02.CN Caterpillar G35166 LE
011 GP02.CN Caterpillar G3516B LE
012 GP02.CN Caterpillar G3516B LE
013 12WE1563.CN Pneumatic Heat Trace Pump
014 12WE1563.CN Pneumatic Heat Trace.Pump
015 12WE1563.CN Fugitive Emission
016 GP02,CN RICE 1085 hp
017 GP02.CN RICE 1680 Hp
018 12WE1563 TEG Dehydrator 39482 48524 11780 46900 11549 79.1
019 GP02 RICE-Waukesha L7044GSI 1068 hp 2378 324 306 184 65 23 355 1.8
020 GP02 RICE-Waukesha L7044GSI 1068 hp 2378 324 306 184 65 .. 23 355 _ 1.8
021 GP02 RICE-Waukesha 1068 hp 2337 318 300 180 1.6
0.0
APEN Exempt/Insignificant Sources 0.0
Produced Water Tank 1 50 156 0.1
Produced Water Vaults 18 56 0.0
Heated Separators 0 0.0
Fugitive Equipment Leaks 3 5 1 2 24 1 0.0
Pig Receiver I 1 5 I 0.0
Compressor Blowdown 3 ,3 1 I 25 3 0.0
TOTAL(tpy) 3.5 0.5 0.5 21.1 24.9 5.9 23.5 15.5 0.4 0.0 95.8
Emissions with controls(Ibsper yeart
POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP TOTAL OPT)
001 12WE1563 Condensate Truck Loadout 4 2 2 2 36 0.0
002 GP01 3-300 bbl condensate Storage 107 533 c 939 0.6
003 GP02.CN Caterpillar
004 GP02.CN Caterpillar
005 GP02 CN Caterpillar
006 GP02 CN Caterpillar G342 NA HCR..
007 GP02.CN Caterpillar G342 NA LCR
008 GP02.CN Cummins KTAI9GC
009 GP02.CN Caterpillar 670 hp
010 GP02.CN Caterpillar G3516B LE
011 GP02.CN Caterpillar G35166 LE
012 GP02.CN . Caterpillar G3516B LE
013 12WE1563.CN Pneumatic Heat Trace Pump
014 12WE1563.CN Pneumatic Heat Trace Pump
015 12WE1563.CN. Fugitive Emissions
016 GP02 RICE 1085 hp ,
017 GP02 RICE 1680 Hp
018 12WE1563 TEG Dehydrator 1887 2357 579 2318 243 3.7
019 GP02 RICE-Waukesha L7044G51 1068 hp 1355 324 306 184 6b 3 23 355 1.3
020 GP02 RICE-Waukesha L7044GSI 1068 hp 1355 324 306 184 65 s 23 355 1.3
021 GP02 RICE-Waukesha 1068 hp 2337 318 300 180 1.6
0.0
APEN Exempt/Insignificant Sources . 0.0
Produced Water Tank 1 50 155 0.1
Produced Water Vaults 18 56 0.0
Heated Separators. 8 0.0
Fugitive Equ�ment Leaks 3 S 1 2 24 1 0.0
Pig Receiver 1 'l. 5 1 0.0
Compressor Slowdown 3 3 1 1 25 3 0.0
TOTAL(tpy) 2.5 0.5 _ '0.5 1.3 1.3 0.3 1.2 0.6 0.4 0.0 8.5
16 12WE1563.CP7 LL 7/16/2020
Hydrocarbon Liquid Loading APE N° a ,d
�r� Cttr- 42018
DPFiE Form APCD-208
+ Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is
filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require
payment for a new filing fee.
This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category,
there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit,
condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN
options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution
Control Division (APCD)website at: www.cvlorado.00vicdphe'apcd.
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: 12WE1563 AIRS ID Number: 123 / 9813/ 001
Section 1 - Administrative Information
Company Name': Bonanza Creek Energy Operating Company, LLC
Site Name: Antelope Section 19 Compressor Station(COGCC#427983)
Site Location
Site Location:
SE/SE Sec 19, T5N, R62W County: Weld
40.37786, -104.35689
NAICS or SIC Code: 1311
Mailing Address:
(Include zip code) 410 17th Street, Suite 1400
Denver, CO 80202 Contact Person: Alisson Soehner
Phone Number: (303) 803-1752
E-Mail Address2: asoehner@bonanzacrk.com
1 Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD.Any changes will require additional paperwork.
2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
- 419743
<oioanoo
Permit Number: 12WE1563 AIRS ID Number: 123 /9$13/001
Section 2 - Requested Action
0 NEW permit OR newly-reported emission source
0 Request coverage under construction permit ❑ Request coverage under General Permit GP07
If General Permit coverage is requested, the General Permit registration fee of$312.50 must be
submitted along with the APEN filing fee.
-OR-
0 MODIFICATION to existing permit (check each box below that applies)
0 Change fuel or equipment ❑ Change company name3
0 Change permit limit ❑ Transfer of ownership4 ❑ Other(describe below)
-OR
APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info& Notes: Truckloading onsite is controlled. APEN is being submitted to
show the reduction in emissions due to control.
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 loading used load condensate into trucks as necessary.
Company equipment Identification No. (optional): L-01
For existing sources, operation began on: 4/10/2012
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area? ✓❑ Yes 0 No
Is this equipment located at a stationary source that is considered a Major Source of(HAP) ❑ Yes D No
emissions?
Does this source load gasoline into transport vehicles? 0 Yes 0 No
Is this source located at an oil and gas exploration and production site? 0 Yes 0 No
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual 0 Yes 0 No
average?
Does this source splash fill less than 6750 bbl of condensate per year? 0 Yes ❑ No
Does this source submerge fill less than 16308 bbl of condensate per year? ❑ Yes 0 No
cope=Aoo
Permit Number: 121NE1563 AIRS ID Number: 123 /9813/001
Section 4 - Process Equipment Information
Product Loaded: 0 Condensate ❑ Crude Oil ❑ Other:
Red-line per If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
attached Requested Volume Loaded5: 61 ,320 bbl/year Actual Volume Loaded: Na/A61,320bb1/year
email recd
June 2, 2020. This product is loaded from tanks at this facility into: tank truck
-11 (e.g. "rail tank cars"or"tank trucks")
If site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor: I Average temperature of 6 A
0.6 bulk liquid loading: �+
Molecular weight of 62 ��
True Vapor Pressure: 6.78 Psia 60 "F lb/lb mol
displaced vapors: .
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year
Product Density: lb/ft3
Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload
5 Requested values will become permit limitations. Requested limit(s)should consider future process growth.
Permit Number: 12WE1563 AIRS ID Number: 123 /9813/001
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.37786/-104.35689
Operator t)ischarge Nutt Above Temp. Flow Rate Velocity
Ground Level
Stack JO No. el) (AMA) (ft/sec)
fleet)
ECD 01-05 -20 500 TBD TBD
Indicate the direction of the stack outlet: (check one)
J❑ Upward O Downward O Upward with obstructing raincap
❑Horizontal O Other(describe):
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter(inches): 48
❑Other(describe):
Section 6 - Control Device Information
0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
❑ Loading occurs using a vapor balance system: Requested Control Efficiency:
Used for control of: VOC, HAPs
Rating: 0.04 MMBtu/hr
Type: Enclosed Make/Model:Five (5) LEED 48" ECDs
rn Combustion
Device: Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98 %
Minimum Temperature: N/A F Waste Gas Heat Content: 3,561 Btu/scf
Constant Pilot Light: El Yes O No Pilot Burner Rating: 0.05 MMBtu/hr
Pollutants Controlled:
O Other: Description:
Requested Control Efficiency:
4 1 kC LCaR a�C
;..
Permit Number: 12WE1563 AIRS ID Number: 123 /9813/001
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(%reduction):
Overall Requested
Pollutant Description of Control Method(s) Control Efficiency
(%reduction in emissions)
PM
SOX
NO.
CO
VOC ECD 95%
HAPs ECD 95%
Other:
❑ Using State Emission Factors (Required for GP07) VOC Benzene n-Hexane
❑Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL
❑Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL
From what year is the following reported actual annual emissions data? 2018
Criteria Pollutant Emissions Inventory
Emission Factor Actual Annual Emissions Requested Annual Permit
Emission Limit(s)5
Pollutant
Uncontrolled Source Uncontrolled 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 N/A <0.01 N/A <0.01
SOX 0.00016 Ib/MMBtu AP-42 N/A <0.01 N/A <0.01
NO. 0.068 Ib/MMBtu AP-42 N/A 0.012 N/A 0.012
CO 0.310 lb/MMBtu AP-42 N/A • 0.053 N/A 0.053
VOC 0.252 lb/bbl SSEF 7.73 0.39 7.73 0.39
Non-Criteria Reportable Pollutant Emissions Inventory
Chemical Emission Factor Actual Annual Emissions
Abstract
Chemical Name Service(CAS Uncontrolled Source Uncontrolled Controlled
) Basis Units (AP-42, Emissions Emissions
6
Number Mfg.,etc.) (pounds/year) (pounds/year)
Benzene 71432 0.0008 lb/bbl SSEF De Minimis De Minimis
Toluene 108883 0.0004 lb/bbl SSEF De Minimis De Minimis
Ethylbenzene 100414 <0.0000 lb/bbl SSEF De Minimis De Minimis
Xylene 1330207 0.0001 lb/bbl SSEF De Minimis De Minimis
n-Hexane 110543 0.0114 lb/bbl SSEF 698 36
2,2,4-
540841 <0.0001 lb/bbl SSEF 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.
n COLORADO
5 . Ailla,\1-I ;,,17 ..-,T.-!'...;
Permit Number: 12WE1563 AIRS ID Number: 123 /9813/001
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 will be operated in full compliance with each condition of General Permit GP07.
1-. 117
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:
✓J 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:r?www.colorado.gov/cdpheiaprd
6 i
6/16/2020 State.co.us Executive Branch Mail-Bonanza Creek-Antelope Section 19 Compressor Station-Permit 12WE1563 Requests
STATE OF
'6: COLORADO Lakocy-CDPHE, Lauraleigh<Iauraleigh.Iakocy@state.co.us>
j j;
Bonanza Creek - Antelope Section 19 Compressor Station - Permit 12WE1563
Requests
Patrick Dilsaver<pdissaver@slrconsulting.com> Tue, Jun 2,2020 at 3:00 PM
To:Alisson Soehner<ASoehner@bonanzacrk.com>, "Lakocy-CDPHE, Lauraleigh"<lauraleigh.lakocy@state.co.us>
Cc: Patrick Dilsaver<PDilsaver@bonanzacrk.com>, Leah Althoff<lalthoff@sIrconsulting.com>
Hey Lauraleigh,
I just copied the questions below with our answers in red. Let us know if you need anything else,or would like to discuss
some of this further.
• On the Form APCD-102, you do not have point 016 or 020 listed as a source, both of which were permitted under a
GP02. I am not finding a copy of either of these cancellations in our records. Meanwhile, you do have point 017 listed
on this form; however, we have a cancellation for this point received August 8, 2018 (Record number 123-9813-144).
Can you provide some clarifications as to which engines are operating at this site? A cancellation for point 016 was
submitted on October 24, 2018 along with Point 010 and 011. I've attached the full package for reference. Point 017
on the submitted 102 form is mislabeled and should be represented as Point 020.
o The TEG Dehydrator is point 018.
• Loadout Questions:
o For the condensate loadout, the APEN reports the 2018 emissions; however,the APEN does not list an actual
throughput in Section 4 of the APEN. Can you please provide the actual volume loaded for 2018 for that
section to be redlined?Actual throughput will be equal to requested throughput, 61,320 bbl/yr, thanks for
catching that.
o Can you provide a sample calculation for how the weight fraction of the THC is calculated from the provided
sales oil composition?Sure, it comes from the truck loading vapor pressure and speciation sheet(attached). I
just copied footnote (e) below, we should have included this in the application;
(e)Vapor Composition (Mole °/0) _ (Constituent TVP. psia) * (Consituent Mole Fraction in Stable Oil)/(Total Liquid
TVP, psia)
Vapor Composition (Wt°/0) _ (Constituent Mole Fraction) * (Consituent MW, lb/lb-mole)/(Total Vapor MW, lb/lb-
mole)
o To clarify,was the estimated HHV estimated using the calculated vapor compositions as calculated by AP-42 or
another method?
The HHV was calculated by summing the product of each components HHV multiplied by its molecular weight%.
The molecular weight% of each component was calculated based on Equation 1-22 of AP 42 Chapter 7.1. The
molecular weight and HHV used can be found on the truck loading vapor pressure and speciation sheet(attached).
• Condensate Tanks Questions:
o Can you submit a screenshot of the working/breathing stencil inputs used to determine the emissions factors? I
did not see this included in the April 2,2019 submission and would like to include this documentation. See
attached image.
o For the combustion emissions,was the combustion of the pilot fuel for the combustion devices included in
these calculations?Including both the combustion of the vapors and the pilot light combustion, I am getting
slightly high emissions for NOx and CO (0.6 tpy and 2.7 tpy, respectively). While this is likely a new request,we
are now calculating and permitting the combustion of the pilot light with the highest emitting source that the
combustion devices control. Updated condensate tank emissions are attached. The pilot flow is now multiplied
by the total amount of combustors used to control emissions-from this source, and we also adjusted the pilot
light flow rate to 18.5 scf/hr from previous correspondence on Antelope F-15. Do you want us to redline this
APEN?
https://mail.google.corn/mail/u/0?ik=44f88835c3&view=pt&search=all&permmsgid=msg-f%3A1668422491097532212&simpl=msg-f%3A16684224910... 1/3
6/16/2020 State.co.us Executive Branch Mail-Bonanza Creek-Antelope Section 19 Compressor Station-Permit 12WE1563 Requests
o As these 2 of these tanks are>472 bbls and are not located prior to custody transfer, can you provide any
clarification as to whether these tanks meet any of the exemptions based on tank vapor pressure for NSPS Kb
or if they are subject to Kb requirements?Although we do not want this to hold up the issuance of the permit,
we would like to make it clear that Bonanza does not agree with this interpretation as the facility is still within
the"producing operations". We would like to note that by determining these tanks are subject to Kb, they are
categorically excluded from OOOO or OOOOa.
• Glycol Dehydrator
o For the control of the flash tank, is there any circumstance in which vapors from the flash tank would be routed
anywhere other than the facility inlet or fuel system? No. it is not physically possible at this site for the flash
tank vapors to be routed anywhere but the facility inlet or to fuel system.
o As this is an existing source, can you provide more information about the combustion device that is used to
control the regenerator? Section 6 of the APEN lists"TBD"or leaves sections blank. The combustor is a Black
Gold Rush BGR18, Serial number BGR18 080618-02.
o For the regenerator emissions, if these emissions are not being routed to the same combustion devices as the
condensate tanks, can you provide the pilot fuel use rate and pilot gas heating value so that these combustion
emissions can be calculated?The combustion emissions for the dehydrator unit have been updated. A pilot
flow rate of 18.5 scf/hr and heating value from the sales gas of 1,395 were used. Please find the updated
calculations attached. CO and NOx increased slightly, however VOC did not increase enough to affect the
controlled emissions.
o How was the waste gas heat content of 668 btu/scf calculated? I think this was put on the APEN wrong it
should be 350.21 and is on the"Dehy Vent Gas"which was included in the application. This is calculated by
multiplying the HHV of each constituent by it's Mol%.
o For the Dehy Inlet Gas sample, the sample pressure was listed as 1125 psig and the sample temperature was
listed as 83 F; however,the pressure and temperature used for the GLYCaIc model was 800 psig and 100 F,
respectively. Can you explain why these values are so different?We have seen with other modeling scenarios
that changes in these parameters can greatly impact the emissions. We have seen this unit run at an average
closer to 800 psig historically. In my experience, a lower pressure results in higher VOC emissions and is more
conservative. This is due to there being less water contacting the TEG, so the TEG picks up more VOC and
emits more when regenerated. This was an attempt to be conservative in our estimations and we can certainly
provide a run at the sample temperature/pressure to compare, if requested.
o On the APEN, the actual and requested dehydrator gas throughput is the same; however,the emissions listed
are not the same. Can you verify that the requested emissions listed on the APEN are correct?And if so, what
throughput did you use to calculate that? Dehy's are a bit unique in that we are required to run monthly Glycalc
runs to demonstrate compliance with actual emissions. As you stated above, actual parameters can cause
fluctuations in the emissions and we wanted to add a safety factor on requested emissions limits to cover this
possibility. The requested throughput would remain the same, but there would be a safety factor to account for
actual monthly parameters causing an increase in emissions when Glycalc is run.
• Just as a quick note, I did notice on the"TEG Dehydrator Criteria and Hazardous Pollutant Emissions
Calculations"sheet,the gas throughput was listed as 30.00 MMscf/yr; however, I think that should be
MMscf/day. This does not appear to impact the calculations, but I wanted to let you know. Yes this is
correct, thanks.
SLR
Patrick Dilsaver
970-494-0805
970-494-0805
307-214-9584
pdilsaver@slrconsulting.com
SLR International Corporation
143 Union Blvd, Suite 505, Lakewood, CO 80228
WINNERS: °SPA'Gr:-.4,71 4SnNNE.R'_ Inter-m. !8a5mess
Alvan 20 17 2016
https://mail.google.co m/mai I/u/0?i k=44f88835c3&view=pt&sea rch=all&permmsg id=msg-f%3A1668422491097532212&simpl=msg-f%3A 16684224910... 2/3
6/16/2020 State.co.us Executive Branch Mail-Bonanza Creek-Antelope Section 19 Compressor Station-Permit 12WE1563 Requests
Confidentiality Notice and Disclaimer
This communication and any attachment(s)contain information which is confidential and may also be legally privileged, It is intended for
the exclusive use of the recipient(s)to whom it is addressed.If you have received this communication in error, please e-mail us by return
e-mail and then delete the e-mail from your system together with any copies of it. Any views or opinions are solely those of the author
and do not represent those of SLR Management Ltd,or any of its subsidiaries, unless specifically stated.
[Quoted text hidden]
[Quoted text hidden]
5 attachments
W&B Stencil.PNG
52K
Ant Sec 19 CLE E-08 E-09 E-10 Cancel 20181024.pdf
1765K
TLO Vapor and Speciation Calcs.pdf
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ANT SEC 19 Tank emissions.pdf
14K
ilk Dehydrator Emissions.pdf
94K
•
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•
Superseded - See APEN Addendum
Attached Received 6/30/2020
Condensate Storage Tank(s) APEN z : _-P,
CDPHE A
Form APCD-205 0p 1 s X013
C4 Air Pollutant Emission Notice (APEN) and 1)
Application for Construction Permit tri'
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is
filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require
payment for a new filing fee.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General
APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website at: www.coiorado.c,ovipacificicdphe/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: 12WE1563 AIRS ID Number: 1 23 / 9813 / 002
Section 1 - Administrative Information
Company Name': Bonanza Creek Energy Operating Company, LLC
Site Name: Antelope Section 19 Compressor Station(COGCC#427983)
Site Location
Site Location: SE/SE Sec 19, T5N, R62W County: Weld
40.37786, -104.35689
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip Code) 410 17th Street, Suite 1400
Denver CO, 80212 Contact Person: Alisson Soehner
Phone Number: (303) 803-1752
E-Mail Address2: asoehner@bonanzacrk.com
1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD.Any changes will require additional paperwork.
2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
- 419747
1
® COLORADO
Permit Number: 12WE1563 AIRS ID Number: 123 /9813/002
Section 2- Requested Action
0 NEW permit OR newly-reported emission source
O Request coverage under traditional construction permit
❑ Request coverage under a General Permit
O GP01 O GP08
If General Permit coverage is requested, the General Permit registration fee of$312.5O must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit(check each box below that applies)
❑ Change in equipment O Change company name3
o Change permit limit O Transfer of ownership' 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
o Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PIE)
Additional Info Et Notes: Condensate tanks were previously permitted under GP01. BCEOC is requesting
traditional construction permit coverage under permit#12WE1563. Emission factors are from previously submitted APEN.
3 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted.
Section 3 - General Information
General description of equipment and purpose: Condensate tank battery used to store condensate.
Company equipment Identification No. (optional):
For existing sources, operation began on: 03/28/2012
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 Et Production(E&P)site ❑ Midstream or Downstream (non EEtP)site
Will this equipment be operated in any NAAQS nonattainment area? 0 Yes I ❑ No
Are Flash Emissions anticipated from these storage tanks? 0 Yes O No
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? ❑ Yes 0 No
If"yes", identify the stock tank gas-to-oil ratio: m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) O Yes 0 No
805 series rules? If so, submit Form APCD-105-
Are you requesting≥6 ton/yr VOC emissions(per storage tank), or are uncontrolled actual ❑ Yes 0 No
emissions≥6 ton/yr(per storage tank)?
l 4 DD
Permit Number: 12WE1563 AIRS ID Number: 123 /9813/002
Section 4 - Storage Tank(s) Information
Actual Annual Amount Requested Annual Permit Limits
(bbl/year) (bbl/year)
Condensate Throughput: 51,100 61,320
From what year is the actual annual amount? TBD
Average API gravity of sales oil: 43.0 degrees RVP of sales oil: 10.1
Tank design: Q Fixed roof ❑ Internal floating roof ❑ External floating roof
Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First
Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production
(bbl) Storage Tank(month/year) (month/year)
CNDTK-01 One(1)300-bbl,Two(2)500-bbl 1,300 3/2O14 3/2O12
Wells Serviced by this Storage Tank or Tank Battery6(MP Sites Only)
API Number Name of Well Newly Reported Well
Compression Station-wells do not directly produce to this site ❑
- ❑
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)
40.37786/-104.35689
Operator Stack Discharge Height Above Temp. Flow Rate Velocity
ID No. Ground Level(feet) (°F) (ACFM) (ft/sec)
ECD 01-05 -20 500 TBD TBD
Indicate the direction of the stack outlet: (check one)
0 Upward ❑Downward ❑Upward with obstructing raincap
❑Horizontal O 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):
3 I 467 F b L 6 R a 0 0
Permit Number: 12WE1563 AIRS ID Number: 123 /9813/002
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
Vapor Size: Make/Model:
❑ Recovery
Unit(VRU): Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented): %
Pollutants Controlled: VOC, HAPs
Rating: 1.84 MMBtu/hr
Type: Enclosed Flare Make/Model:Five (5) LEED 48" ECDs
❑ Combustion Requested Control Efficiency: 95
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: N/A Waste Gas Heat Content: 2,624 Btu/scf
Constant Pilot Light: ❑ Yes El 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)? —50 psig
Describe the separation process between the well and the storage tanks:
Compressor liquids are sent from scrubbers directly to tanks, pigging liquid is transferred from
pipeline to an on-site heated slug catcher and then directed to tanks.
77',"
Permit Number: 12WE1563 AIRS ID Number: 123 /9813/002
Section 8 - 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(%reduction):
Overall Requested Control
Pollutant Description of Control Method(s) Efficiency
(%reduction in emissions)
VOC ECD 95%
NOx
CO
HAPs ECD
Other:
From what year is the following reported actual annual emissions data? 201 8
Criteria Pollutant Emissions Inventory
Requested Annual Permit
Emission Factor Actual Annual Emissions
Emission Limit(s)5
Pollutant
Source Uncontrolled Controlled Uncontrolled Controlled
Uncontrolled Units (AP-42, Emissions Emissions8 Emissions Emissions
Basis Mfg.,etc.) (tons/year) y ) (tons/year)
(tons/year) (tons/ ear tons! ear)
VOC 9.93 lb/bbl SSEF 253.80 12.69 304.56 15.23
NOx 0.068 lb/MMBtu AP-42 N/A 0.46 N/A 0.55
CO 0.310 Ib/MMBtu AP-42 N/A 2.09 N/A 2.51
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 Emissions8
Number Basis
Mfg.,etc.) (pounds/year) (pounds/year)
Benzene 71432 0.035 lb/bbl SSEF 1,776 90
Toluene 108883 0.017 lb/bbl SSEF 884 46
Ethylbenzene _ 100414 0.001 lb/bbl SSEF De Minimis De Minimis
Xylene 1330207 0.002 lb/bbl SSEF De Minimis De Minimis
n-Hexane 110543 0.306 lb/bbl SSEF 15,644 784
2,2,4- 540841 0.001 lb/bbl SSEF 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.
n,� co aeaoo
5i m
Permit Number: 12WE1563 AIRS ID Number: 1 23 /9813/002
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.
51 //4‘el?_- • 7. 1
� l 7
Signature of Legally Authorized Person (not a vendor or consultant) Date
Alisson Soehner Environmental Engineer, Air Quality
Name (print) Title
Check the appropriate box to request a copy of the:
Draft permit prior to issuance
0✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with$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.00v cdpheiapcd
„AQ] £Oi ROADO
6 I
Received June 30, 2020
Condensate Storage Tank(s) APEN
`` .r Form APCD-205 C CDPHE Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment
for a new filing fee.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General
APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website.
This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 12WE1563 AIRS ID Number: 123 / 9813 /002
[Leave blank unless APCD has already assigned a permit•and AIRS ID]
Section 1 - Administrative Information
Company Name: Bonanza Creek Energy Operating Company, LLC
Site Name: Antelope Section 19 Compressor Station(COGCC#427983)
Site Location
Site Location:
SE/SE Sec 19, T5N, R62W County: Weld
40.37786, -104.35689
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip Code) 410 17th Street, Suite 1400
Denver CO, 80202 Contact Person: Alisson Soehner
Phone Number: (303) 803-1752
E-Mail Address2: asoehner@bonanzacrk.com
1 Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD.Any changes will require additional paperwork.
2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
COLORADO
Form APCD-205 Condensate Storage Tank(s) APEN - Revision 12/2019 1 I °"°�`"""°"
Permit Number: 12WE1563 AIRS ID Number: 123 /9813/002
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 2 - Requested Action
❑ NEW permit OR newly-reported emission source
O Request coverage under traditional construction permit
❑ Request coverage under a General Permit
❑ GP01 ❑ GP08
If General Permit coverage is requested, the General Permit registration fee of$312.50 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment 0 Change company name3
❑ Change permit limit ❑ Transfer of ownership4 ❑ Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
❑ APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit (PTE)
Additional Info£t Notes: Condensate tanks were previously permitted under GP01. BCEOC is requesting
traditional construction permit coverage under permit#12WE1563. Emission factors are from previously submitted APEN.
3 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted.
Section 3 - General Information
General description of equipment and purpose: Condensate tank battery used to store condensate.
Company equipment Identification No. (optional):
For existing sources, operation began on: 3/28/2012
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
Storage tank(s) located at: El Exploration a Production (EEtP)site ❑ Midstream or Downstream (non EftP)site
Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ❑ No
Are Flash Emissions anticipated from these storage tanks? 0 Yes 0 No
Is the actual annual average hydrocarbon liquid throughput≥ 500 bbl/day? ❑ Yes 0 No
If"yes", identify the stock tank gas-to-oil ratio: m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) ❑ Yes El No
805 series rules? If so, submit Form APCD-105.
Are you requesting≥6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual ❑ Yes ❑✓ No
emissions≥6 ton/yr(per storage tank)?
aCOLORADO
Form APCD-205 Condensate Storage Tank(s) APEN- Revision 12/2019 2 I
Permit Number: 12WE1563 AIRS ID Number: 123 /9813/002
[Leave blank unless APCD has already assigned a permit;i and AIRS ID
Section 4 - Storage Tank(s) Information
Actual Annual Amount Requested Annual Permit Limits
(bbl/year) (bbl/year)
I Condensate Throughput: 51,100 61,320
From what year is the actual annual amount? 2018
Average API gravity of sales oil: 43.0 degrees RVP of sales oil: 10.1
Tank design: ❑r Fixed roof 0 Internal floating roof 0 External floating roof
Storage #of liquid Manifold Storage Total Volume of Installation Date of Most Date of First
Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production
(bbl) Storage Tank(month/year) (month/year)
CNDTK-01 One(1)300-bbl,Two(2)500-bbl 1,300 3/2014 3/2012
Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only)
API Number Name of Well Newly Reported Well
Compression Station-wells do not directly produce to this site ❑
CI
CI
CI
El
5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider
future process growth. Requested values are required on all APENs,including APEN updates.
6 The E&P Storage Tank APEN Addendum (Form APCD-212)should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.37786/-104.35689
0 Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Operator Stack Discharge Height Above Temp. Flow Rate Velocity
ID No. Ground Level(Feet) (°F) (ACFM) (ft/sec).
ECD 01-05 —20 500 TBD TBD
Indicate the direction of the stack outlet: (check one)
✓❑Upward ❑Downward ❑Upward with obstructing raincap
❑Horizontal ❑Other(describe):
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter(inches): 48
❑Square/rectangle Interior stack width (inches): Interior stack depth(inches):
o Other(describe):
COLORADO
� N��
Form APCD-205 Condensate Storage Tank(s) APEN - Revision 12/2019 3 xb���
Permit Number: 12WE 1563 AIRS ID Number: 123 /9813/002
[Leave blank unless APCD has already assignee a permit#and AIRS ID
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
Vapor Size: Make/Model:
❑ Recovery
Unit (VRU): Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented): %
Pollutants Controlled: VOC, HAPs
Rating: 2.04 MMBtu/hr
hr
Type: Enclosed Flare Make/Model: Five (5) LEED 48" ECDs
❑ Combustion Requested Control Efficiency: 95 %
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: N/A Waste Gas Heat Content: 2 624 Btu/scf
t
Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 0.05 MMBtu/hr
Description of the closed loop system:
O Closed Loop System
Pollutants Controlled:
❑ Other: Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (E£tP 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:
Compressor liquids are sent from scrubbers directly to tanks, pigging liquid is transferred from
pipeline to an on-site heated slug catcher and then directed to tanks.
�/a COLORADO
Form APCD-205 Condensate Storage Tank(s) APEN. - Revision 12/2019 4 �! Hmtf�6 EnnWnment
Permit Number: 12WE1563 AIRS ID Number: 123 /9813/002
[Leave blank unless APCD has already assigned a permit#and AIRS 10]
Section 8 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form7.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes 0 No
If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Pollutant Control Equipment Descri Description Collection Efficiency Control Efficiency
p (—of total emissions captured (%reduction of captured
by control equipment) emissions)
VOC ECD 100 95
NOx
CO
HAPs ECD 100 95
Other:
•
From what year is the following reported actual annual emissions data? 201 8
Use the following table to report the criteria pollutant emissions from source:
Emission Factor? Actual Annual Emissions Requested Annual Permit
Pollutant Emission Limit(s)5
Source Uncontrolled Controlled Uncontrolled Controlled
Uncontrolled Units (Ap-42, Emissions Emissions$' Emissions Emissions
Basis Mfg.,etc.)
(tons/year); (tons/year) (tonslyear) (tonstyear)
VOC 9.93 Ib/bbl SSEF 253.80 12.69 304.56 15.23
NOx 0.068 Ib/MMBtu AP-42 0.52 0.52 0.63 0.63
CO 0.310 Ib/MMBtu AP-42 2.36 2.36 2.77 2.77
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs,including APEN updates.
7 Attach condensate liquid laboratory analysis,stack test results,and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Section 9 - Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteria Yes 0 No
pollutants (e.g. HAP- hazardous air pollutant) equal to or greater than 250 lbs/year?
If yes, use the following table to report the non-criteria pollutant (HAP)emissions from source:
Chemical '` Emission Factor? Actual Annual Emissions
Chemical Name Abstract Source Uncontrolled Controlled
ncont
Service(CAS) U Units (AP-42, � !Emissions Emissions8
Number ' BasisrolledMfg-,etc.) (tbslyeor) (lbs/year)
Benzene 71432 0.035 Ib/bbl SSEF 1,776 90
Toluene 108883 0.017 Ib/bbl SSEF 884 46
Ethylbenzene 100414 0.001 Ib/bbl SSEF De Minimis De Minimis
Xylene 1330207 0.002 Ib/bbl SSEF De Minimis De Minimis
n-Hexane 110543 0.306 Ib/bbl SSEF 15,644 784
2,2,4-Trimethylpentane 540841 0.001 Ib/bbl SSEF De Minimis De Minimis
7 Attach condensate liquid laboratory analysis,stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Aril',Am(COLORADO
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 12/2019 5n°
Permit Number: 12WE 1563 AIRS ID Number: 123 /9813/002
[Leave blank unless APCD has already assigned a permit 0 and AIRS ID?
Section 10 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
ri- 6/30/2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
Alisson Soehner Environmental Engineer,Air Quality
Name (print) Title
Check the appropriate box to request a copy of the:
❑✓ Draft permit prior to issuance
✓0 Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit For more information or assistance call:
registration fee of$312.50, if applicable, to:
Small Business Assistance Program
Colorado Department of Public Health and Environment (303) 692-3175
Air Pollution Control Division OR
APCD-SS-B1 (303) 692-3148
4300 Cherry Creek Drive South
Denver, CO 80246-1530 APCD Main Phone Number
(303) 692-3150
Make check payable to:
Colorado Department of Public Health and Environment
COLORADO
Form APCD-205 Condensate Storage Tank(s) APEN - Revision 12/2019 6 x m
cOPFiE Glycol Dehydration Unit APEN SEP 1 a 2013
Form APCD-202 .=
CO
� Air Pollutant Emission Notice (APEN) and 1€.tP 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 glycol dehydration (dehy)units 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, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200)is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD)website 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-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: 12WE1563 AIRS ID Number: 123 / 9813 /018
Section 1 - Administrative Information
Company Name': Bonanza Creek Energy Operating Company. LLC
Site Name: Antelope Section 19 Compressor Station(COGCC#427983)
Site Location
Site Location:
SE/SE Sec 19, T5N, R62W County: Weld
40.37786, -104.35689
NAICS or SIC Code: 1311
Mailing Address:
(Include bp Code) 410 17th Street, Suite 1400
Denver CO, 80212 Contact Person: Alisson Soehner
Phone Number: (303) 803-1752
E-Mail Address=: asoehner@bonanzacrk.com
Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD.Any changes will require additional paperwork.
2Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
419746
,
61,i COlORn6G
•
Permit Number: 12WE1563 AIRS ID Number: 123/98'3/018
Section 2 - Requested Action
O NEW permit OR newly-reported emission source
-OR-
✓❑ MODIFICATION to existing permit (check each box below that applies)
0 Change fuel or equipment O Change company name3 O Add point to existing permit
O 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: Updated to include the new inlet gas composition and remove stripping gas from the model.
This APEN is being submitted to reflect the change in emissions associated with the dehydrator operating changes.
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: - Natural Gas Dehydration
30 MMscf/d TEG Unit with (2) Kimray PV45015 glycol pumps (1 for backup)and a 1.0 MMBtu/hr reboiler heater
Company equipment Identification No. (optional): DEHY-01
For existing sources, operation began on: 02/26/2019
For new or reconstructed sources, the projected start-up date is:
p 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
0 Yes No
nonattainment area?
❑
Is this unit located at a stationary source that is considered
a Major Source of(HAP) Emissions? ❑ Yes No
hr, COIORnDO
Permit Number: 12WE1563 AIRS ID Number: 123/98'3/018
Section 4 - Dehydration Unit Equipment Information
Manufacturer: QB Johnson Manufacturing Model Number: N/A
Dehydrator Serial Number: 769318 Reboiler Rating: 1 .0 MMBTU/hr
Glycol Used: O Ethylene Glycol (EG) ❑ DiEthylene Glycol (DEG) ✓❑ TriEthylene Glycol(TEG)
Glycol Pump Drive: O Electric ✓❑ Gas If Gas, injection pump ratio: 0.080 / Acfm/gpm
Pump Make and Model: Kimray PV45015 #of pumps: 2(1 backup)
Glycol Recirculation rate (gal/min): Max: 7.5 Requested: 7.5
Lean Glycol Water Content: 1 .5 Wt.%
Design Capacity: 30 MMSCF/day
Dehydrator Gas Throughput:
Requested5: 10,950 MMSCF/year Actual: 10,950 MMSCF/year
Inlet Gas: Pressure: 800 psig Temperature: 1 00 F
Water Content: Wet Gas: lb/MMSCF ✓❑ Saturated Dry gas: 5.0 lb/MMSCF
Flash Tank: Pressure: 1 20 psig Temperature: 1 20 F O NA
Cold Separator: Pressure: psig Temperature: F ✓❑ NA
Stripping Gas: (check one)
0 None O Flash Gas O Dry Gas O Nitrogen
Flow Rate: scfm
Additional Required Information:
0 Attach a Process Flow Diagram
0 Attach GRI-GLYCalc 4.0 Input Report 8 Aggregate Report(or equivalent simulation report/test results)
0 Attach the extended gas analysis(including BTEX a n-Hexane, temperature, and pressure)
5 Requested values will become permit limitations. Requested limit(s)should consider future process growth.
® CC?,OR aDp
Permit Number: 12WE1563 AIRS ID Number: 123/9813/016
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.37786/-104.35689
Operator Discharge Height Temp. Flow Rate Velocity
Above Ground Level
Stack ID No, ('F) f M) (ft/set)
(feet)
DEHY-01 -10 -1000 -1.2 TBD
Indicate the direction of the stack outlet: (check one)
p Upward O Downward O Upward with obstructing raincap
❑Horizontal O Other(describe):
Indicate the stack opening and size: (check one)
✓❑Circular Interior stack diameter(inches): TBD
❑Square/rectangle Interior stack width (inches): Interior stack depth (inches): .
❑Other(describe):
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Used for control of:
❑ Condenser: Type: Make/Model:
Maximum Temp: F Average Temp: F
Requested Control Efficiency:
Used for control of:
❑ VRU: Size: Make/Model:
Requested Control Efficiency:
VRU Downtime or Bypassed:
Used for control of: Regenerator
Rating: TBD MMBtu/hr
Red-lines per attached
email reed 6/2/2020. Combustion Type: TBD ECI) Make/Model: Black Gold Rush BGRI8
LL ❑✓ Device: Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: N/A F Waste Gas Heat Content: 668 Btu/scf
Constant Pilot Light: Yes ❑ No Pilot Burner Rating: N/A MMBtu/hr
Closed Used for control of: Flash Tank
0 Loop Description: Flash vapors are sent to the facility inlet.As a backup the vapors are sent to the fuel system.
System: System Downtime: 0
Used for control of:
❑ Other: Description:
Requested Control Efficiency:
VCCrlOR4UO
Permit Number: 12V E 1563 AIRS ID Number: 123/98'3/018
Section 7.- Emissions Inventory Information
Attach all emission 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
SO.
NO.
CO
VOC ECD 95%
HAPs ECD 95%
Other:
From what year is the following reported actual annual emissions data? N/A
Criteria Pollutant Emissions Inventory
Emission Factor Actual Annual Emissions Requested Annual Permit
Emission Limit(s)5
Pollutant
Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled
Basis Units (AP-42, Emissions Emissions6 Emissions Emissions
Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year)
PM 40.0 pg/L AP-42 N/A 0.23 N/A 0.27
SO. 0.000 Ib/MMBtu AP-42 N/A 0.00 N/A 0.00
NO,, 0.068 Ib/MMBtu AP-42 N/A 0.21 N/A 0.25
CO 0.310 Ib/MMBtu 1 AP-42 N/A 0.94 N/A 1.12
VOC 66.49 ( lb/MMscf GRI-GLYCaIc 4.0 364.01 7.05 436.81 8.46
Non-Criteria Reportable Pollutant Emissions Inventory
• Chemical Emission Factor Actual Annual Emissions
Chemical Name Abstract Source Uncontrolled Controlled
Service(CAS) Uncontrolled Units (AP•4Z, Emissions Emissions6
Basis
Number Mfg.,etc.) (pounds/year) (pounds/year)
Benzene 71432 3.00 lb/MMscf GRI-GLYCaIc 4.0 32902 1573
Toluene 108883 I 3.69 Ib/MMscf GRI-GLYCaIc40 40437 1964
Ethylbenzene 100414 0.90 Ib/MMscf GRI-GLYCalc40 9817 483
Xylene 1330207 3.57 Ib/MMscf,GRI-GLYCatc4.0 39083 1932
n-Hexane 110543 0.88 lb/MMscf GRI-GLYCaIc 4.0 9624 203
2,2,4-
540841 0.0001 Ib/MMscf GRI-GLYCaIc 4A
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.
COi O+z A£DO
_ _ .. 5 i ....
Permit Number: 12WE1563 AIRS ID Number: 123/9813/018
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
(4?ig /,')171/ q./60 /
Signature of Legally Authorized Person (not a vendor or consultant) Date
Alisson Soehner Environmental Engineer, Air Quality
Name (print) Title
Check the appropriate box to request a copy of the:
El Draft permit prior to issuance
✓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 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-B 1
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.cotorado.gov/cdpheiapcd
COLOR 4Dq
6I
6/16/2020 State.co.us Executive Branch Mail-Bonanza Creek-Antelope Section 19 Compressor Station-Permit 12WE1563 Requests
STATE OF Lakocy-CDPHE, Lauraleigh<lauraleigh.lakocy@state.co.us>
Kf' COLORADO
Bonanza Creek - Antelope Section 19 Compressor Station - Permit 12WE1563
Requests
Patrick Dilsaver<pdilsaver@slrconsulting.com> Tue,Jun 2, 2020 at 3:00 PM
To:Alisson Soehner<ASoehner@bonanzacrk.com>, "Lakocy-CDPHE, Lauraleigh"<lauraleigh.lakocy@state.co.us>
Cc: Patrick Dilsaver<PDilsaver@bonanzacrk.com>, Leah Althoff<lalthoff@slrconsulting.com>
Hey Lauraleigh,
I just copied the questions below with our answers in red. Let us know if you need anything else,or would like to discuss
some of this further.
• On the Form APCD-102, you do not have point 016 or 020 listed as a source, both of which were permitted under a
GP02. I am not finding a copy of either of these cancellations in our records. Meanwhile, you do have point 017 listed
on this form; however,we have a cancellation for this point received August 8, 2018 (Record number 123-9813-144).
Can you provide some clarifications as to which engines are operating at this site? A cancellation for point 016 was
submitted on October 24, 2018 along with Point 010 and 011. I've attached the full package for reference. Point 017
on the submitted 102 form is mislabeled and should be represented as Point 020.
o The TEG Dehydrator is point 018.
• Loadout Questions:
o For the condensate loadout,the APEN reports the 2018 emissions; however,the APEN does not list an actual
throughput in Section 4 of the APEN. Can you please provide the actual volume loaded for 2018 for that
section to be redlined?Actual throughput will be equal to requested throughput. 61,320 bbl/yr, thanks for
catching that.
o Can you provide a sample calculation for how the weight fraction of the THC is calculated from the provided
sales oil composition? Sure, it comes from the truck loading vapor pressure and speciation sheet(attached). I
just copied footnote (e) below, we should have included this in the application;
(e)Vapor Composition (Mole %) = (Constituent TVP: psia) " (Consituent Mole Fraction in Stable Oil)/(Total Liquid
TVP, psia)
Vapor Composition (Wt°/0) = (Constituent Mole Fraction) *(Consituent MW, lb/lb-mole)/(Total Vapor MW, lb/lb-
mole)
o To clarify, was the estimated HHV estimated using the calculated vapor compositions as calculated by AP-42 or
another method?
The HHV was calculated by summing the product of each components HHV multiplied by its molecular weight°/0.
The molecular weight`)/0 of each component was calculated based on Equation 1-22 of AP 42 Chapter 7.1. The
molecular weight and HHV used can be found on the truck loading vapor pressure and speciation sheet(attached).
• Condensate Tanks Questions:
o Can you submit a screenshot of the working/breathing stencil inputs used to determine the emissions factors? I
did not see this included in the April 2,2019 submission and would like to include this documentation. See
attached image.
o For the combustion emissions,was the combustion of the pilot fuel for the combustion devices included in
these calculations? Including both the combustion of the vapors and the pilot light combustion, I am getting
slightly high emissions for NOx and CO(0.6 tpy and 2.7 tpy, respectively). While this is likely a new request,we
are now calculating and permitting the combustion of the pilot light with the highest emitting source that the
combustion devices control. Updated condensate tank emissions are attached. The pilot flow is now multiplied
by the total amount of combustors used to control emissions from this source, and we also adjusted the pilot
light flow rate to 18.5 scf/hr from previous correspondence on Antelope F-15. Do you want us to redline this
APEN?
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o As these 2 of these tanks are>472 bbls and are not located prior to custody transfer, can you provide any
clarification as to whether these tanks meet any of the exemptions based on tank vapor pressure for NSPS Kb
or if they are subject to Kb requirements?Although we do not want this to hold up the issuance of the permit,
we would like to make it clear that Bonanza does not agree with this interpretation as the facility is still within
the"producing operations". We would like to note that by determining these tanks are subject to Kb, they are
categorically excluded from OOOO or OOOOa.
• Glycol Dehydrator
o For the control of the flash tank, is there any circumstance in which vapors from the flash tank would be routed
anywhere other than the facility inlet or fuel system? No, it is not physically possible at this site for the flash
tank vapors to be routed anywhere but the facility inlet or to fuel system.
o As this is an existing source, can you provide more information about the combustion device that is used to
control the regenerator? Section 6 of the APEN lists"TBD"or leaves sections blank. The combustor is a Black
Gold Rush BGR18, Serial number BGR18 080618-02.
o For the regenerator emissions, if these emissions are not being routed to the same combustion devices as the
condensate tanks, can you provide the pilot fuel use rate and pilot gas heating value so that these combustion
emissions can be calculated?The combustion emissions for the dehydrator unit have been updated. A pilot
flow rate of 18.5 scf/hr and heating value from the sales gas of 1,395 were used. Please find the updated
calculations attached. CO and NOx increased slightly, however VOC did not increase enough to affect the
controlled emissions.
o How was the waste gas heat content of 668 btu/scf calculated? I think this was put on the APEN wrong it
should be 350.21 and is on the"Dehy Vent Gas"which was included in the application. This is calculated by
multiplying the HHV of each constituent by it's Mol%.
o For the Dehy Inlet Gas sample, the sample pressure was listed as 1125 psig and the sample temperature was
listed as 83 F; however, the pressure and temperature used for the GLYCaIc model was 800 psig and 100 F,
respectively. Can you explain why these values are so different?We have seen with other modeling scenarios
that changes in these parameters can greatly impact the emissions. We have seen this unit run at an average
closer to 800 psig historically. In my experience, a lower pressure results in higher VOC emissions and is more
conservative. This is due to there being less water contacting the TEG. so the TEG picks up more VOC and
emits more when regenerated. This was an attempt to be conservative in our estimations and we can certainly
provide a run at the sample temperature/pressure to compare, if requested.
o On the APEN, the actual and requested dehydrator gas throughput is the same; however,the emissions listed
are not the same. Can you verify that the requested emissions listed on the APEN are correct?And if so, what
throughput did you use to calculate that? Dehy's are a bit unique in that we are required to run monthly Glycalc
runs to demonstrate compliance with actual emissions. As you stated above, actual parameters can cause
fluctuations in the emissions and we wanted to add a safety factor on requested emissions limits to cover this
possibility. The requested throughput would remain the same, but there would be a safety factor to account for
actual monthly parameters causing an increase in emissions when Glycalc is run.
■ Just as a quick note, I did notice on the"TEG Dehydrator Criteria and Hazardous Pollutant Emissions
Calculations"sheet,the gas throughput was listed as 30.00 MMscf/yr; however, I think that should be
MMscf/day. This does not appear to impact the calculations, but I wanted to let you know. Yes this is
correct, thanks.
SLR
Patrick Dilsaver
970-494-0805
970-494-0805
307-214-9584
pdilsaver@slrconsulting.com
SLR International Corporation
143 Union Blvd, Suite 505, Lakewood, CO 80228
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5 attachments
W&B Stencil.PNG
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Ant Sec 19 CLE E-08 E-09 E-10 Cancel 20181024.pdf
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TLO Vapor and Speciation Calcs.pdf
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ANT SEC 19 Tank emissions.pdf
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ill Dehydrator Emissions.pdf
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