The URL can be used to link to this page

Browse Search

Home My WebLink About20191473.tiffCOLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 April 9, 2019 Dear Sir or Madam: RECEIVED APR 1 5 2019 WELD COUNTY COMMISSIONERS On April 11, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Bonanza Creek Energy Operating Company, LLC - Mustang Y-34 Production Facility (COGCC# 450213). 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: Clara Gonzales Regards, A Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor tbb\‘G ).�,Q,u ) , I22I►O I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer c c: PLCTP)1�lt -r), pw(sr'(e,1zlct IC' - 4115/19 2019-1473 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Bonanza Creek Energy Operating Company, LLC - Mustang Y-34 Production Facility (COGCC# 450213) - Weld County Notice Period Begins: April 11, 2019 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: Mustang Y-34 Production Facility (COGCC# 450213) Exploration Ft Production Well Pad SESE quadrant of Section 34, Township 4N, Range 63W Weld County The proposed project or activity is as follows: Initial application for a new EItP Wellsite 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): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • 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 18WE1022 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: Ben Fischbach Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 RADO COLORADO Air Pollution Control Division Evpantt:ent of r1:hic Health & EmaTanmeot Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 18WE1022 Issuance: 1 Bonanza Creek Energy Operating Company, LLC Facility Name: Plant AIRS ID: Physical Location: County: General Description: Mustang Y-34 Production Facility (COGCC# 450213) 123/9FF4 SESE SEC 34 T4N R63W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description CNDTK 001 Three (3) 500 barrel fixed roof storage vessels used to store condensate Enclosed Flare PWT-01 002 One (1) 500 barrel fixed roof storage vessel used to store produced water Enclosed Flare ECD-01 003 Flaring of produced Gas from a high- pressure separator. Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Page 1 of 11 COLORADO Air Pollution Control Division Department M Public Health & E vimnment Dedicated to protecting and improving the health and environment of the people of Colorado Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. 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 shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion, date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall 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 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO CNDTK ' 001 --- 1.3 15.6 6.1 Point PWT-01 002 --- 0.3 0.4 1.2 Point ECD-01 003 --- 9.7 60.4 44.4 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 shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. Page 2 of 11 COLORADO Air Pollution Control Division Department of T§:biic Health & 6n eranreent Dedicated to protecting and improving the health and environment of the people of Colorado The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall 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 shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled CNDTK . 001 Enclosed Flare VOC and HAP PWT-01 002 Enclosed Flare VOC and HAP ECD-01 003 Enclosed Flare VOC and HAP PROCESS LIMITATIONS. AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit CNDTK 001 Condensate throughput 233,892 barrels PWT-01 002 Produced Water throughput 148,920 barrels ECD-01 003 Natural Gas Venting 180 MMSCF Compliance with the annual throughput limits shall 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 shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. Point 003: The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator Page 3 of 11 COLORADO Air Pollution Control Division Depa%tm- °r^ of i1. tgic Health & Env ronniant Dedicated to protecting and improving the health and environment of the people of Colorado shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. Point 001: This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 13. Point 001, 002, and 003: The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. Points 001 and 002: The storage tanks covered by this permit are subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.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. Page 4 of 11 COLORADO Air Pollution Control Division Depaninent nt Pi.b ie Health Ex Enva; onment Dedicated to protecting and improving the health and environment of the people of Colorado 15. Points 001 and 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, Section XVII.C.2. 16. Point 003: The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING £t MAINTENANCE REQUIREMENTS 17. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OFtM 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 18. Point 001: The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A17) 19. Points 001, 002, and 003: A source initial compliance test shall be conducted to measure the emission rate for volatile organic compounds (VOC) in order to demonstrate compliance with a minimum destruction efficiency of 98% for VOCs. The test shall determine the mass emission rates of volatile organic compounds at the inlet and outlet of the control device, which shall be used to determine the destruction efficiency during the test. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. (Regulation Number 3, Part B., Section III.G.3) Periodic Testing Requirements 20. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 21. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: Page 5 of 11 COLORADO Air Pollution Control Division Depa-tr cnt o€ Pubitc Health & Envfmnm.rcet Dedicated to protecting and improving the health and environment of the people of Colorado 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; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or No later than 30 days before the existing APEN expires. 22. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 23. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 24. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation Page 6 of 11 COLORADO Air Pollution Control Division Depa-a gent of Public Health 8 Envannment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 25. 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. 26. 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. 27. 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 shall constitute a rejection of the entire permit and upon such occurrence, this permit shall 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. 28. 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. 29. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Ben Fischbach Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Bonanza Creek Energy Operating Company, LLC Page 7 of 11 COLORADO Air Pollution Control Division Depa-t e,nt n' Tk b1 c Health & Eni;tanreent 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 shall 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 shall 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 listedto inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) Benzene 71432. 7,967 159 001 Toluene 108883 8,036 161 Ethylbenzene 100414 1,016 20 Xylenes 1330207 2,658 53 n -Hexane 110543 149,443 2,989 2,2,4- Trimethylpentane 540841 326 7 002 Benzene 71432 1,042 21 n -Hexane 110543 3,276 66 003 Benzene 71432 23,126 464 Toluene 108883 28,552 572 Ethylbenzene 100414 4,978 100 Xylenes 1330207 16,268 326 n -Hexane 110543 167,044 3,342 Page 8 of 11 COLORADO Air Pollution Control Division Department of TLbitc Health & En••Aron rent Dedicated to protecting and improving the health and environment of the people of Colorado 2,2,4- Trimethylpentane 540841 120 2 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source N0x 0.0113 0.0113 AP -42 Ch. 13.5 CO 0.0516 0.0516 AP -42 Ch. 13.5 V0C 6.66 0.13 ProMax 71432 Benzene 0.034 0.001 ProMax 108883 Toluene 0.034 0.001 ProMax 100414 Ethylbenzene 0.004 0.0001 ProMax 1330207 Xylene 0.011 0.0002 ProMax 110543 n -Hexane 0.640 0.013 ProMax 540841 2'2'4 Trimethylpentane 0.001 2.79E-5 ProMax Note: The controlled emissions factors for this point are based on the flare control efficiency of 98%. Point 002: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source N0x 0.0037 0.0037 AP -42 Ch. 13.5 CO 0.0167 0.0167 AP -42 Ch. 13.5 V0C 0.262 0.01 CDPHE 71432 Benzene 0.007 1.4E-4 CDPHE 110543 n -Hexane 0.022 4.4E-4 CDPHE Note: The controlled emissions factors for this point are based on the flare control efficiency of 98%. Point 003: CAS # Pollutant Uncontrolled Emission Factors lb/MMSCF Controlled Emission Factors lb/MMSCF Source N0x 108.1 108.1 AP -42 Ch. 13.5 CO 492.8 492.8 AP -42 Ch. 13.5 V0C 33,556 671.1 Mass Balance 71432 Benzene 128.5 2.57 Mass Balance Page 9 of 11 COLORADO Air Pollution Control Division Gepa tmenc o€ Pine Health & t:n,a; onment Dedicated to protecting and improving the health and environment of the people of Colorado CAS # Pollutant Uncontrolled Emission Factors lb/MMSCF Controlled Emission Factors lb/MMSCF Source 108883 Toluene 158.6 3.17 Mass Balance 100414 Ethylbenzene 27.6 0.55 Mass Balance 1330207 Xylene 90.4 1.81 Mass Balance 110543 n -Hexane 928 18.56 Mass Balance Note: The controlled emissions factors for this point are based on the flare control efficiency of 98%. The emission factors listed above are based on modeled separator temperature of 110 °F and separator pressure of 75 psig. 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 shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, Benzene, Toluene, n -Hexane, Total HAPs PSD or NANSR Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z Page 10 of 11 COLORADO Air Pollution Control Division nepanrr,ent of R.b @c Health & Enrranm=_nt Dedicated to protecting and improving the health and environment of the people of Colorado 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 11 of 11 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Ben Fischbach Package 8: 387846 Received Date: 9/18/2018 Review Start Date: 2/6/2019 Section 01- Facility Information Company Name: Bonanza Creek Energy Operating Company, LLC County AIRS ID: .123 Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: Exploratlo(ii &Produdtion Well Pad`fi What industry segment? Oil &Natural Gas Production Si Processing Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ carbon Monoxide (Co) ❑ Pardcdate Matter (PM) p ozone (NOx & VOC) 9FF4 Mustang Y-34 Production. Facility (COGCC#450213) SESE quadrant of Section 34, Township 4N, Range 63W Weld County Quadrant Section Township Range SESE 34, 4N 63 Section 02 - Emissions Units In Permit Application Yes AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit 8 Issuance # Self Cert Required? Action Engineering Remarks 001 "s `P Condensate Tank k CNDTK - - -- Yes 18W01022 - 1 Yes ;. Permit Initial '. r Issuance 002 Produced Water Tank PWT-01 Yes 18W91022 1 Yes Permit Initial Issuance 003 -' -` ;;;- Separator Venting .. FL -2 , - , Yes 18WE1022 1 Yes Permit Initial r. Issuance Section 03 - Description of Project Operator is requesting anew synthetic minor construction permit for a well production facility servicing a single well (Longhorn V41-3-4XRLNB).Applicant indicates that, due to lack ofpipeline. infrastructure in the area, all production gas will be routed to enclosed combustors. Applicant is requesting 98% destruction efficiency for the enclosed combustor. Section 04- Public Comment Requirements Is Public Comment Required? If yes, why? ='Requesting Synthetic Minor Permit Section 05 -Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? Na 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? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration IPSO) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) No " Yes SO2 NOx CO VOC PM2.5 PM10 TSP HAPs o r: ❑ ❑ ❑ ❑ O 0020 000 0 SO2 NOx CO VOC PM2.5 PM10 TSP HAPs ❑ 0000 0 O 0000 000 0 0 Condensate Storage Tank(s) Emissions Inventory 001 Condensate Tank 'Facility AIRS ID: . 023 County Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Threeffilbatr9lfltedxoofsiotage Description: Emission Control Device t4y$4d ntbfis oy_; Description: Requested Overall VOC & HAP Control Efficiency it: Section 03- Processing Rate Infomnation for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput= ". 194;930 Barrels (bbl) per year 'Requested Permit Limit Throughput = Potential to Emit (PTE) Condensate Throughput= Condensate. Ira. Actual Condensate Throughput While Emissions Controls Operating = Requested Monthly Throughput = Model Values Modeled Throughput = VOC Emissions Benzene Emissions Toluene Emissions Ethylbenzene Emissions Xylene Emissions n -Hexane Emissions 224 TMP Emissions Barrels (bbl) per year Barrels (bbl) per year 21.354 Barrels (bbl( per hour 142.1620572 lb/hr 0.727347 lb/hr 0.733686 lb/hr 0.0927745 lb/hr 0.24265 lb/hr 13.6439 lb/hr 0.0297513 lb/hr Secondary Emissions - Combustion Device(s) Heat content of waste gas= ., 2B01 Btu/scf Volume of waste gas emitted per BBL of liquids produced = '1.S1$5Sa3 scf/bbl Actual heat content of waste gasrouted to combustion device = Requested heat content of waste gas routed to combustion device = 32,825 MMBTU per year 39,310 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 39,310 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Pollutant ®'MMESEIMIIME Pollutant Uncontrolled Controlled (Ib/bbl( (lb/bbl) (Condensate Throughput) R;.i^.6.65740. 0.03406 °x;0.03436 fucA!' ";0.00434 A 0.63394 ' : 0:00139 ,=L" (Condensate Throughput) Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (waste heat eom busted) (Ib/6bl) (Condensate Throughput) Emission Factor Source Emission Factor Source Section 05 - Emissions Inventory Criteria Pollutants Pctential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) VOC PM10 PM2.5 NOx CO 778.6 648.8 13.0 778.6 15.6 2645 0.0 0.0 0.0 0.0 0.0 0 0.0 0.0 0.0 0.0 0.0 0 1.3 1.1 1.1 1.3 1.3 227 6.1 5.1. 5.1 6.1 6.3 1035 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) fibs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 2247MP 7967 6639 133 7967 159 8036 6697 134 8036 161 1516 847 17 1016 20 2658 2215 44 2658 53 149443 124536 2491 149443 2989 326 272 5 326 7 Section 06- Regulatory Suns Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section Xll.C, 01, F Storage tank is subject to Regulation 7, Section Xll.C-F Regulation 7, Section OILS, C Storage Tank is not subject to Regulation 7, Section 011.4 Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subjectto Regulation 7, Section XVII, B, Cl & C.3 Regulation 7, Section XVII.C,2 Storage tank is subjectto Regulation 7, Section XVII.C.2 Regulation 6, Part A, NIPS Subpart Kb Storage Tank is not subject to NIPS Kb Regulation 6, Part A, NIPS Subpart 0000 Storage Tank is not subject to NSPS 0000 Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MALI HH (See regulatory applicability worksheet for detailed analysis) 194,910 Barrels (bbl) per year 19865 Barrels (bbl( per month ' Annual heat content Equations altered to reflect/include pilot fuel throughput of 0.15 MMScf/yr 2 of 14 K:\PA\2018\18 W E1D22, CP1 Condensate Storage Tank(s) Emissions Inventory Section 07- Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based one pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site - specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company request a contol device efficiency greater than 95%for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Operator ran P oMaz in non-traditional wayn m Rather than starting with analyzed (post -separator) streams, hack -calculated individual Condensate Gas, and Water streams winch were thexed and sent to the initial separate, unit: Operators seeminglyback-:salved. for streams which would provide similar compositions to the gas end condensate streams post -separator. Streamsseem to patch up fine - w will sour initial approval and require initial sampling inpermit Control Device Description: Crvnson CE 1000 Enclosed Combustor. Rated @ 4 MMBtu/nr, Waste gas heat content =2661 tttu/scf. Operator is requesting 11% control efficiency. AIRS Point g 001 Process P SCC Code 01 Uncontrolled Emissions Pollutant Factor PM10 0.00 0 PM2.5 0.00 0 NOx 0.27 0 VOC 158.5 98 CO 1.24 0 Benzene 0.81 90 Toluene 0.82 98 Ethylbenzene 0.10 98 Xylene 0.27 98 n -Hexane 15.21 98 224 TMP 0.03 98 Section 09 - Inventory SCC Coding and Emissions Factors Control % Units b/1,000 gallons condensate throughput 6/1,000 gallons condensate throughput 6/1,000 gallons condensate throughput 6/1,000 gallons condensate throughput 6/1,000 gallons condensate throughput 6/1,000 gallons condensate throughput 6/1,000 gallons condensate throughput bl1,000 gallons condensate throughput. 6/1,000 gallons condensate throughput 4/1,000 gallons condensate throughput b/1,000 gallons condensate throughput 3 of 14 Kt\PA\2018\18W E1022.CP1 Condensate Tan kRegu latory Analysis Worksheet Colorado Regulation 3 Parts Aand B -ADEN and Permit Requirements Source Is in the Non -..foment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greaterthan 2 TPY (Regulation 3, Part A, Section II.D.S.a)? 2, Is the construction date (service date) priorto 12/30/2002 and not modified after 12/31/2002 (See PS Memo 0S-01 Definitions1.12 andl.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are totalfadlty uncontrolled VOL emissions greaterthan 5TPY, NOx greaterthan lO TPY or CO embsions greaterthan 10 TPY (Regulation 3, Partt, Section ll.D3)? You have indicated that source Is In the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled em''sions from any criteria pollutants from this individual source greater than 1TPY (Regulation 3, Part A, Section ll.D.I.a)? 2. Is the construction date (service date) priorto 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2for additional guidons on grandfather applicability)? 3. Are total facility uncontrolled VOCemissions greater than 2'WY, NOx greaterthan 5TPY or CO emissions greater than lorry (Regulation 3, Part B, Section 11.0.2)? Source requires a permit Colorado Regulation]. Section 011.0-F 1. Isthb storage tank located lathe 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operations, natural gas compressorsteion or natural gas drip station? 3. Isth's storage tank located upstream of a natural gas procrosing plant? 'Storage tank Is subject to Regulation 7, Section XII.C-F Section XII.CS —General Requirements for Air Pollution Control Equipment —Prevention of Leakage Section Xll.C.2—Emission Estimation Procedures Section XIID—Enlssions Control Requirements Section XII.E-6ontoring Section XII.F—Recordkeeping and Reporting Colorado Regulation, Section 101.8 1, Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is thb storage tank located at a natural gas processing plant? 3. Does the storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greaterthan or equal to 2 tons peryearVOC? 'Storage Tank is not subject to Regulation 7, Section XII.0 Section XII.0.2,Emissions Control Requirements Section XII.C.1 —General Requirements for Alr Pollution Control Equipment —Prevention of Leakage Section XII.C.2 —Emission Estimation Procedures Colorado Regulation 7, Section MI 1. Is this tank located at a transmission/storage facility? 2. Is this condensate storage tanks located at an oil and gas exploration and production operation , well production facility`, natural gas compresorstationa or natural gas processing plant? 3. Is this condensate storage tank afixed roof storage tank? 4. Are uncontrolled actual emissions ofthlestarage tank equal to or greaterthan 6 tons per year VOC? 'Storage tank is subject to Regulation 7, Section XVII, R, C.1610.3 Section XNI.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.o- Emissions Control and Monitoring Provisions Section XVII.C3- Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabilized" liquids? 'Storage tank is subject to Regulation 7, Section XVILC.2 Section XVII.C.2 -Capture and Moneoringfor Storage Tanks fitted with Air Pollution Control Equipment 40 CFR. Part60. Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greaterthan or equal to 75 cubic meters (ma) (`472 BBLs(? 2. Does the storage vessel meet the fnlmwing exemption in 6o.111b(d)(4)? a. Dom the vessel has a design capacity less than or equal to 1.589.874 ma ("'10,000 BBL] used for petroleums or condensate stored, processed, ortreated priorto custody transfer as defined in 60.1116? 3. Was this condensate storage tank constructed, recnstruced, or modified (see definitions 40 CFR, 602) afterluly 23, 1984? 4. Does the tank meet the definition of "storage valeta in 60.1116? 5. Does the storagevessel store e"volatile organic liquid (VOL"s as defined in 60.11lb? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is tie storage vessel a pressure vessel designed to operate in excess of 204.9 kPa (-29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity Is greaterthan or equal to 151 ma ("950 BBL] and stores a liquid with a maximum true vapor pressure` less than 35 kPa (60.1106(6))?; or c The design capacity is greaterthan or equal to 75 Ma (-472 BBL) but Igs than 151 ma ("950 BBL. and storm a liquid wish a maximum true vapor pressure° less than 15.0 kPa(60.110b(b))? Yes Yps' a.' Yes Yes Yes No No Yes 3YR Source Req Go to next. Source Req Continue-' Continue-' Source is sc Continue StorageTar Continue Go to the Go to then Source is s5. Go to the n StorageTar Storage Tank ie not subject to NSPS Kb Subpart A, General Provisions §601126 - Emissions Control Standards forVOC 460.1136 -Testing and Procedures §60115b - Reporting and Recordkeeping Requirements 460116b - Monitoring of Operations 40 CFR, Part60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Pmductloe. Transmission and Dirtdbud0n I. 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? 2. Was this condensate storage vessel constructed,reconstructed, or modified (see definitions 4o CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emisslonsr from the Individual storage vessel greater than or equal to Stotts per year? 4. Does this condensate storage vessel meet the definition of "storage vessel"' per 605430? 5. Is the storage vase) subjectto and controlled In accordance with requirements forstorage vessels in 40 CFR Part 60 Subpart Kb 0r40 CFR Pant 63 Subpart HH? 'Storage Tent is not subject to NSPS 0000 Subpart A, General Provisions per 4605425 Table 3 460.5395 - Emissions Control Standards for VOC §60.5413 -Testing and Procedures 460.5395(x) -Notification, Reporting and Recordkeeping Requirements §60.5416(c(-Coverand Closed Vent System Monitoring Requirements 060.5417 -Control Device Monitoring Requirements [Nate: If a storage vessel Is previously determined to be subjectto NSPS 0000 due to emissions above tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365)e)12( even if potential VOC emissions drop below 6 tons per year] 40 CFR. Part 63, Subpart MACn HH, Oil and Gas Production Facilities I. Is the storagertank located atan oil and natural gas production facility that meets either of the fallowing ateria: a. Afaciliy that processes, upgrades orstere hydrocarbon liquids. (63.760(a)(2)(; OR b. ATacility that processes, upgrades orstores natural gas priorto the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.760(a)(3))? 2. Is the tank located ate facility that is major for HAPs? 3. Does the tank meet the definition of "storage veselr° in 63.761? 4. Does the tank meet the definition of"storage vessel with the potential for flashembsions"s per63.761? 5. Is the tank subject to control requirements under40 CFR Part 60, Subpart Kb or Subpart 0000? 'Storage Tank is not sdbjed to MACT HH SabpartA, General provisions per 463.764 (a) Tablet §63.766 -Emissions Control Standards §63.773 -Monitoring §63.774- Recordkeeping 463.775 -Reporting RACT Review PACT review Is required if Regulation 7 does not apply AND If the tank is In the man -attainment area. If the tank meets bath criteria, then review RAGS requirements. Disclaimer This document assists operators with determining eppicabdHy 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 A contains may not apply toe particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any otherlegaly binding requirement and is not legally enforceable. In the event of any con0ictbetween 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 APCDinte pmtations and recommendation. 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. Yes Continue StorageTar Storage Tar Yes (Continue-' Storage Tar Produced Water Storage Tank(s) Emissions Inventory 002 Produced Water Tank acility AlRs ID: 9Ff 4- Plant 12 Point Section 02- Equipment Description Details Detailed Emissions Unit One (1) 500 barrel fixed roof storage vessel used to store produced water. Description: Emission Control Device - z z Enclosed Combustor Description: Requested Overall VOC & HAP Control Efficiency %: 98 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions -Storage Tank(s) Actual Produced Water Throughput = Requested Permit Limit Throughput= ":.11484,20; Barrels (bbl) per year Requested Monthly Throughput= 12648 Barrels (bbl) per month 1204001. Barrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating= Potential to Emit (PTE) Produced Water Throughput = Barrels (bbl) per year Secondary Emissions - Combustion Device(s) "t "d�tr{R �4 6sa Heat content of waste gas= 96s Btu/scF Volume of waste gas emitted per BBL of liquids produced = 36:' scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 6,684 MMBTU per year 8,020 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 8,020 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Pollutant Produced Water Tank Uncontrolled Controlled (lb/bbl) (lb/bbl) (Produced Water Throughput) 0.007 Pollutant 0.022 (Produced Water Throughput) 1.40E-04 0.000 0.000 0.000 4.40E-04 0.000 Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat combusted) 0.0680' 0.3100=., (Produced Water Throughput) 0.0000 0.0000 0.0037 0.0167 Emission Factor Source Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) VOC PM10 PM2.5 NOx CO 19.5 16.3 0.3 19.5 0.4 66 0.0 0.0 0.0 0.0 0.0 0 0.0 0.0 0.0 0.0 0.0 0 0.3 0.2 0.2 0.3 0.3 46 1.2 1.0 1.0 1.2 1.2 211 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TM 1042 869 17 1042 21 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 3276 2730 55 3276 66 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, Cl & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 (See regulatory applicability worksheet for detailed analysis) 5 of 14 K:\PA\2018\18 W E1022.CP1 Produced Water Storage Tank(s) Emissions Inventory Section 07- Initial and Perioric Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it maybe appropriate to use an older site=specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. Does the company request a control device efficiency greater than 95%for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 002 Process # SCC Code 01 4-04-003-15 Fixed Roof Tank, Produced Water, wnrking+breathing+Flashing losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons liquid throughput PM2.5 0.00 0 lb/1,000 gallons liquid throughput NOx 0.09 0 lb/1,000 gallons liquid throughput VOC 6.2 98 lb/1,000 gallons liquid throughput CO 0.40 0 lb/1,000 gallons liquid throughput Benzene 0.17 98 lb/1,000 gallons liquid throughput Toluene 0.00 98 lb/1,000 gallons liquid throughput Ethylbenzene 0.00 98 lb/1,000 gallons liquid throughput Xylene 0.00 98 lb/1,000 gallons liquid throughput n -Hexane 0.52 98 lb/1,000 gallons liquid throughput 224 TMP 0.00 98 lb/1,000 gallons liquid throughput 6 of 14 K:\PA\2018\18WE1022.CP1 Produced Water Storage Tank Regulatory Analysis Worksheet Please note that IMPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb. Colorado Regulation 3 Parts A and B - APEN and Permit Requirements 'Source is In the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section ll.D.1.a)? 2. Is the operator claiming less than 1% crude oil and is thetank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section 11.0.1.M) 3. Are total fadlhy uncontrolled VOC emissions greater than 5TPY, NOx greater than 10TPt or CO emissions greater than to TPY (Regulation 3, Part 0, Section 11.0.3)? 'Youhave indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than 1TPY (Regulation 3, Part A, Section ll.D.1.a)? 2. Is the operator claiming less than 1% crude oil and isthe tank located at a non-commerdal facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 2TPY, Not greater than 5 TPY or CO emissions greater than 1OTPY (Regulation 3, Part B, Section 11.0.2)7 (Source requires a permit Colorado Regulation 7, Section XVII 1. Is this tank looted at a transmission/storage facility? 2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station' or natural gas processing plant? 3. Is this produced water storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions°ofthis storage tank equal to or greater than 6 tons per year VOL? 'Storage tank k subject to Regulation 7, Section XVII, B, c.1& C.3 Section XVII.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C3- Emissions Control and Monitoring Provisions Section XVII.C3- Recordkegptng Requirements 5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. 'Storage tank is subject to Regulation 7, Section XVIl.C.2 Section XVII.C.2- Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR. Part 60, Subpart oeoO, Standards of Performance for Crude Oil and Natural Gas Production: Transmission and Distribution 1. Is this produced water 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? 2. Was this produced water storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions' from the Individual storage vessel greater than or equal to 6 tons per year? 4. Does this produced water storage vessel meet the definition of "storage vessel"' per 605430? 'Storage Tank is not subject to NSPS 0000 Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 -Testing and Procedures §60.5395(g)- Notification, Reporting and Recordkeeping Requirements §60.5416(c) -Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements (Nate: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subjectto NSPS 0000 per 60.5365(e)(2) even if potential VOC emissions drop below 6tons per year) RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. X the tank meets both criteria, then review RACT requirements. Qisclaimer 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. No Yea Yes Source Req Go to next . Source Req Continue-` tontine -r Go to the n Source lssc Source issl. Continue-` Storage Tar Separator Venting Emissions Inventory 003 Separator Venting (Facility AIRs ID: 123 County 9FF4 Plant 103 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description Venting of produced Gas from a high-pressure separator. Enclosed Combustor Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput 180. MMscf per year 98 Requested Permit Limit Throughput 180:0. MMscf per year Requested Monthly Throughput= 15 MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: 180 MMscf per year Secondary Emissions -Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Section 04 - Emissions Factors & Methodologies 1590 Btu/scf scf/bbl Description Due to a lackof pipeline infrastructure, produced gas from a three phase separators vented through an enclosed flare. Emission factors are based on gas venting throughput process parameter'and a representative extended gas analysis pulled from a nearby and similar site, Gas sample pulled from separator operating at 75 psig and 110F. MW 27.9 Weight Helium CO2 N2 methane ethane propane isobutane n -butane isopentane n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224-TMP Benzene Toluene Ethylbenzene Xylenes C8+ Heavies 0.16 9 0.91 33.87 1622 18.98 3.06 9.57 2.62 3.49 0.32 1.26 0.35 2.00 0.46 0.00 0.17 0.22 0.04 0:12 1.70 Total VOC Wt 100.00 45.60 h/lb-tool Displacement Equation Ex=Q*MW*Xx/C Emission Factors Separator Venting Pollutant VOC Benzene Toluene Ethylbenzene Xylene n -Hexane Uncontrolled Controlled (lb/MMscf) (lb/MMscf) (Gas Throughput) 33568.3377 28.1633 158.2718 27.6792 90.1781 927.5462 224 IMP 0.6625 (Gas Throughput) 671.3668 3.1654 0.5536 1.8036 L8.5509 0.0133 Primary Control Device Uncontrolled Uncontrolled Emission Factor Source Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 : 0.000 P M 2.5 0,000 sox 0.000 NOx CO 0.0680 108,088 100 492.754 *NOTE: Used operator/APEN listed EF's in annual calculations (G69 -G75), as only differences are due to rounding differences/errors (379 vs 379.3 scf/Ib-mol). APEN Listed EF's Uncontrolled 33556.11 lb/MMscf 128.48 lb/MMscf 158.62 lb/MMscf 27.66 lb/MMscf 90.38 lb/MMscf 928.02 Ib/MMscf 0.67 lb/MMscf t )polled a rs 671-122222 lb/MMscf 2.56955556 lb/MMscf 3.17244444 lb/MMscf 0.55311111 lb/MMscf 1.80755556 lb/MMscf 18.5604444 lb/MMscf 0.01333333 lb/MMscf 8 of 14 K:\PA\2018\18 W E1022,CP1 Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 P542.5 sox NOx VOC CO 0.00 0.00 0.00 0.00 0,00 0 0.00 0.00 0.00 0.00 0.00 0 a.00 0.00 o.o0 0.00 0.00 0 9.73 9.73 9.73 9.73 9.73 1652 3020.05 3020.05 60.40 3020.05 60.40 10260 44.35 44.35 44.35 44.35 44.3 7533 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) Fin/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 23069 23126 463 23126 463 28489 28552 571 28552 571 4982 4978 100 4978 100 16232 16268 325 16268 325 167044 167044 3341 167044 3341 119 120 2 120 2 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII. B, G Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Source requires a permit Source is subject to Regulation 7, Section XVII.B,2, G The control device for this separator Is not subject to Regulation 7, Section XVII.B.2.e Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRS ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? If yes, the permit will contain: -An "Intial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are lessthan or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require a owe 9 of 14 K:\PA\2018\18WE1022.CP1 Separator Venting Emissions Inventory Section 09 - Inventory SCC Coring and Emissions Factors AIRS Point# 003 Process# SCC Code 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control% Units PM10 0.00 0 Ib/MMSCF PM2.5 0.00 0 Ib/MMSCF S0x 0.00 0 lb/MMSCF N0x 108.09 0 lb/MMSCF V0L 33568.34 98 lb/MMSCF CO 492.75 0 Ib/MMSCF Benzene 128.16 98 lb/MMSCF Toluene 158.27 98 lb/MMSCF Ethylbenzene 27.68 98 lb/MMSCF Xylene 90.18 98 Ib/MMSCF n -Hexane 927.55 98 Ib/MMSCF 224 TMP 0.66 98 Ib/MMSCF 10 of 14 K:\PA\2018\18 W E1022.CP1 Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B -APEN and Permit Re. eirements Isour a is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greaterthan 2 TPY (Regulation 3, Part A, Section ll.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5TPY, NOR greater than 10TPY or CO emissions greater than 1OTPY (Regulation 3, Part B, Section 11.0.31? Not enough information NON -ATTAINMENT 1. Are uncontrolled. Emissions from any criteria pollutants from this individual source greater than OTPY (Regulation 3, Part A, Section ll.D.1.o)? 2. Aretotal facility uncontrolled VOC emissions from the greater than 2TPY, NOx greater than 5 TPY or CO emissions greater than 1OTPY (Regulation 3, Part B, Section 11.0.21? 'Source requires a permit Colorado Regulation 7, section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1,2014? (Source Is subject to Regulation 7, Section XVII.B.2, G Section XVII.B.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section) Is this separator controlled by a back-up or altemate combustion device (I.e., not the primary control device) that is not enclosed? 'The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e Section XVII.B.2.e—Alternative emissions control equipment Disclaimer Thisdocument assists operators with determining applicability of certain requirements of the Clean Air Act, ifs 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" end "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. Y5 in Source Req Source Req The control COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Bonanza Creek Energy Operating Company, LLC 123 9FF4 Mustang Y-34 Production Facility (COGCC# 460213) History File Edit Date 3/8/2019 Ozone Status Non -Attainment EMISSIONS - Uncontrolled (tons per year EMISSIONS With Controls (tons per year POIN T AIRS PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 18WE1022 Condensate Tanks - 3 a 500 bbl 1.2 737.8 5.4 81.4 1.2 14.8 5.4 1.6 New Point 002 18WE1022 Produced Water Tank -1 a 500 bbl 0.3 19:5 1.2 2.2 0.3 0.4 1.2 0.0 New Point 003 18WE1022 Process (LP) Gas Flaring 9.7 3,020.5 44.4 120.0 9.7 60.4 44.4 2.4 New Point 004 GP07 Truck Loading 0.0 0.0 0.0 27.6 0.1 0.5 0.0 0.0 0.0 10.0 0.1 0.0 New Point 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APEN Exempt/Insignificants 0.0 0.0 XA Heated Separators 0.3 0.3 0.0 0.3 0.3 0.0 New Point - From APCD102 XA Pneumatic Devices 1 3.1 0.1 3.1 0.1 New Point - From APCD102 XA Fugitive EquipmgntL@aks 0.1 0.0 0.1 0.0 New Point - From APCD102 0.0 0.0 FACILITY TOTAL 0.0 0.0 0.0 0.0 11.6 3,808.5 0.1 51.4 204.2 0.0 0.0 0.0 0.0 11.5 88.7 0.1 61.4 4.2 VOC: Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Minor (OP) HAPS: Syn Minor B, T, n -Hex & Total Permitted Facility Total 0.0 0.0 0.0 0.0 11.2 a805.4 0.0 51.1 204.0 0.0 0.0 0.0 0.0 11.2 85.6 0.0 51.1 4.1 Excludes units exempt from (O) Change in Permitted Emissions 0.0 0.0 0.0 0.0 11.2 85.6 0.0 51.1 Pubcom & modeling (not) required based on (A change in emissions) Note 1 Total VOC Faci D) Change in Total Permitted VOC ity Emissions (point and fugitive emissions (point and fugitive 88.8 Facility is eligible for GP02 because < 90 Project emissions less than 25/50 tpy 85.6 Note 2 Page 12 of 14 Printed 4/8/2019 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 9FF4 Facility Name Mustang Y-34 Production Facility (COGCC# 450213) Emissions - uncontrolled (lbs per year POIN" PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene , Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tPY) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE1022 Condensate Tanks - 3 (a) 500 bbl 7650 7720 984 2574 143446 328 81.4 002 18WE1022 Produced Water Tank - 1 @ 500 bbl 1044 3278 2.2 003 18WE1022 Process (LP) Gas Flaring 23126 28552 4978 16268 167044 120 120.0 004 GP07 Truck Loading 96 842 0.5 0.0 0.0 0.0 0.0 0.0 0.0 APEN Exempt/Insignificants 0.0 XA Heated Separators 7 0.0 XA Pneumatic Devices 1 23 29 5 17 169 0.1 XA Fugitive Equipment Leaks 1 1 1 4 0.0 0.0 TOTAL (tpy) 0.0 0.0 0.0 16.0 18.1 3.0 9.4 157.3 0.0 0.2 0.0 0.0 204.0 otal Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus 13 18WE1022.CP1 4/8/2019 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 9FF4 Facility Name Mustang Y-34 Production Facility (COGCC# 450213) Emissions with controls (Ibs oer year POIN-PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tPY) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE1022 Condensate Tanks - 3 (a) 500 bbl 153 154 20 51 2869 7 1.6 002 18WE1022 Produced Water Tank - 1 @ 500 bbl 21 66 0.0 003 18WE1022 Process (LP) Gas Flaring 464 572 100 326 3342 2 2.4 004 GP07 Truck Loading 2 17 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APEN Exempt/Insignificants 0.0 XA Heated Separators 7 0.0 XA Pneumatic Devices 1 23 29 5 17 169 0.1 XA Fugitive Equipment Leaks 1 1 1 4 0.0 0.0 TOTAL (tpy) 0.0 0.0 0.0 0.3 0.4 0.1 0.2 3.2 0.0 0.0 0.0 0.0 4.1 14 18WE1022.CP1 4/8/2019 Condensate Storage Tank(s) APEN RECEIVED Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit SEP 1 8 2018 All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. 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.colorado.gov/pacific/cdphe/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: -FsTro MINE 107,i AIRS ID Number: 123 IC? F f+ J fj APCD StuFlonitry Sowpsh [Leave blank unless APCD has already assigned a permit # and MRS ID] Section 1 - Administrative Information Company Name: Bonanza Creek Energy Operating Company, LLC Site Name: Mustang Y-34 Production Facility (COGCC# 450213) Site Location: SESE S34 T4N R63W 40.262061, -104.416133 Mailing Address: (include zip Code) 410 17th Street, Suite 1400 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address2: Alisson Soehner (303) 803-1752 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. 387842 Form APCD-205 - Condensate Storage Tanks) APEN - Revision 7/2018 1 I A COLORADO t`c'' _ Pr_,: Permit Number: TBD AIRS ID Number: 1 23 / / [Leave blank unless sPCD has already assigned a permit ft and PARS ID] Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit ❑ Request coverage under a General Permit O GP01 O GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment O Change company name3 ❑ Change permit limit O Transfer of ownership4 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Initial E&P wellsite application 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: Company equipment Identification No. (optional): For existing sources, operation began on: The tank battery will be used for condensate storage prior to it being trucked out. 06/20/2018 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 weeks/year O Exploration Et Production (E@P) site ❑ Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? 0 Yes • No Are Flash Emissions anticipated from these storage tanks? El Yes I No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? IS Yes • No If "yes", identify the stock tank gas -to -oil ratio: 0.0107 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No • 'A Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No • FA COLORADO Form Az°CD-2O5 - Condensate Storage Tank(s) APEN - Revision 7/2018 Permit Number: TBD AIRS ID Number: 1 23 / / [Leave blank unless APCD has already assigned a permit N and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limits (bbl/year) Condensate Throughput: 194,910 233,892 From what year is the actual annual amount? Average API gravity of sales oil: 39.3 degrees Tank design: ❑✓ Fixed roof ❑ Internal floating roof RVP of sales oil: 7.5 ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) CNDTK (3) 500 -bbl 1,500 06/2018 06/2018 Wells Serviced by this Storage Tank or Tank Battery6 (EEtP Sites On y) API Number Name of Well Newly Reported Well 05 - 123 - 44702 Longhorn V41-3-4XRLNB 151 ■ ■ - ■ ■ 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) 40.262061, -104.416133 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) ECD-01 35 Indicate the direction of the stack outlet: (check one) ❑ Downward ❑ Other (describe): Q Upward ❑ Horizontal Indicate the stack opening and size: (check one) Circular ❑ Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): 96 Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 ly.COLORADO Permit Number: TBD AIRS ID Number: 1 23 I [Leave blank unless APCD has already assigned 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. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): % Combustion ❑ Device: Pollutants Controlled: VOC, HAP Rating: Type: 4 Enclosed Combustor Make/Model: Crimson CE 1 000 MMBtu/hr Requested Control Efficiency: 98 Manufacturer Guaranteed Control Efficiency: 98 % x,661 IPei 61" Minimum Temperature: N/A Constant Pilot Light:❑ Yes ❑ No Pilot Burner Rating: Waste Gas Heat Content: 2,452 Btu/scf MMBtu/hr N/A El Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 - Gas/Liquids Separation Technology Information (EttP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 75 psig Describe the separation process between the well and the storage tanks: The well produces into a single stage 3 -phase separator where condensate is separated out and routed to the condensate tank battery. Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 7/2018 COLORADO 4I T.F.,,� Permit Number: TBD AIRS ID Number: 1 23 / [Leave blank unless APCD has already assigned a permit tt and AIRS ID] 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): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECD 98 NOx CO HAPs ECD 98 Other: From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Tons/ ear y ) Controlled Emissions (Tons/year) (Tons/ ear Uncontrolled Emissions (Tons/ � r) y r(Tons/year) Controlled Emissions VOC 6-a08J6.65 } lb/bbl ProMax 4.0 $ 614.79(, %' 12.3013,0 -6�$ 0 14.76I c.6 NOx 0.068 Ib/MMBtu AP -42 N/A 4-98 1.1 N/A 4,-2e I.3 CO 0.310 Ib/MMBtu AP -42 N/A 4.54-5.1 N/A 5.11- 6.1 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number - Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled Emissions8 (Pounds/year) Benzene 71432 0.0327 439 lb/bbl ProMax 4.0 4.24 133 0,372 (C39 Toluene 108883 0.038001.d3'j lb/bbl ProMax 4.0 G.,`ell tse 034 0,428 Ethylbenzene 100414 0.0012O,Wi3 lb/bbl ProMax 4.0 844- vi 1- 'i 8 11r Xylene 1330207 -9-o,Q1I lb/bbl ProMax 4.0 2,126 all5 -44 LI li n -Hexane 110543 lb/bbl ProMax4.O 149;§2613'-1,834 2,392 atilt) 0.613(,y(, 2,2,4-540841 Trimethylpentane 0.00140,44 110/10101 ProMax4.0 262r+1 6 r 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. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 5 I�j COLORADO Permit Number: TBD AIRS ID Number: 1 23 / [Leave blank unless APCD has already assigned a permit ti and AIRS IDI Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signature of Legally Authorized Person (not a vendor or consultant) Alisson Soehner Name (print) Date Environmental Engineer, Air Quality Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 COLORADO 6 :T t 3/26/2019 State.co.us Executive Branch Mail - Mustang Y-34 Permit Application Redline Patrick Dilsaver <pdilsaver@slrconsulting.com> To: "Fischbach - CDPHE, Ben" <ben.fischbach@state.co.us> Cc: Alisson Soehner <asoehner@bonanzacrk.com> Ben, Fri, Mar 8, 2019 at 10:59 AM Yes the flow meter for this point is currently installed and operational, since November 2018 from what I'm seeing. Thanks! [Quoted text hidden] Fischbach - CDPHE, Ben <ben.fischbach@state.co.us> Fri, Mar 8, 2019 at 2:17 PM To: Patrick Dilsaver <pdilsaver@slrconsulting.com> Hey Pat, Thanks for the info! It looks like the monitoring frequencies for the control devices will switch from weekly to daily in the O&M plan given the throughput increase and facility wide VOC emissions going over 80 tpy - could you please send new O&M plans for the condensate tanks, produced water tanks, and produced gas flaring? Thanks again! Ben [Quoted text hidden] Patrick Dilsaver <pdilsaver@slrconsulting.com> To: "Fischbach - CDPHE, Ben" <ben.fischbach@state.co.us> Cc: Nissan Soehner <asoehner@bonanzacrk.com> Ben, See attached for the updated O&M plans. [Quoted text hidden] 0514A-`a•”bi'•.4iGsnlA:w2a:'CJY. Jbet..L71?GwA AM.L.IOCv.CaAYA::O9.SS:TS.bW9w'iCI Y,,gelikriCe c4,y0W SX NO•attJ.Watke,,H.C'S:f6Nf+6LiP.<vi'NLYN3.l:.L::4lSSA:O.A:)R:rKn Mustang Y-34 Updated O&M Plans.pdf 423K Sat, Mar 9, 2019 at 10:01 AM Fischbach - CDPHE, Ben <ben.fischbach@state.co.us> Mon, Mar 11, 2019 at 3:44 PM To: Patrick Dilsaver <pdilsaver@slrconsulting.com> Hi Pat, I'm getting some slightly disagreement between our emission factor calculations for the condensate tanks. For example, for VOC: Looking at the "Oil Total Tank Emissions" stream, I'm calculating 142.162 Ib/hr of VOC emissions. From the "Flashed Oil" stream I'm getting 21.354 bbl/hr for condensate tank throughput. Dividing the two gives me a VOC emission factor of 6.657 lb/bbl, a bit higher than what was reported on the APEN (I'm getting similar disagreement for all of the HAP emission factors as well). https://mail.google.com/mail/u/0?ik=0ddl cdaf99&view=pt&search=all&permthid=thread-f%3A1624737411799893199&simpl=msg-f%3A16247374117... 6/12 326/2019 State.co.us Executive Branch Mail - Mustang Y-34 Permit Application Redline I can go ahead and redline those NOx and CO emissions on my end, and thanks for getting me the sample analysis. Comparing it to the calculation sheet that you included with the redline, it seems that the weight percent of the components listed on your calculation sheet all differ slightly from those on the gas analysis, which is causing some minor disagreements between our calculations. I can't find where the weight percents listed on the calculation sheet are coming from, are they from your own conversion of mole percent to mass percent? Thanks, Ben [Quoted text hidden] Patrick Dilsaver <pdilsaver@sIrconsulting.com> Thu, Feb 21, 2019 at 10:44 AM To: "Fischbach - CDPHE, Ben" <ben.fischbach@state.co.us>, Alisson Soehner <asoehner@bonanzacrk.com> Ben, We do use the "Gas Analysis Sheet" that I sent over to calculate Wt% from mol %, and I think the difference is just our conversion from mol% to wt%. For an example, I believe the difference you are seeing for n -hexane is 1.2620% (spreadsheet caics) vs. 1.2580% (lab sheet). I believe the difference is due to rounding and fairly small N.3%). It also looks like all Wt% in our calcs are conservative and slightly higher than the lab report. Let me know if you want to change anything here. Thanks, [Quoted text hidden] [Quoted text hidden] f_s AMDX S Fischbach - CDPHE, Ben <ben.fischbach@state.co.us> To: Patrick Dilsaver <pdilsaver@sirconsulting.com> Hey Pat, Thu, Feb 21, 2019 at 11:34 AM No need to change any of it - just wanted to make sure teat's where the differences were coming from. Thanks, Ben [Quoted text hidden] Fischbach - CDPHE, Ben <ben.fischbach@state.co.us> Fri, Mar 8, 2019 at 9:55 AM To: Patrick Dilsaver'<pdilsaver@slrconsuiting.com> Hey Pat, Is the flow meter for point 003 (separator venting/flaring) currently installed and operational? Thanks, Ben [Quoted text hidden] https://mail.google.com/mail/u/0?ik=Odd 1 cdaf99&view=pt&search=al(&permthid=thread-f%3A1624737411799893199&simpl=msg-f%3A16247374117... 5/12 3/26/2019 State co us Executive Branch Mail - Mustang Y-34 Permit Application Redline Thanks' Alisson Alisson Soehner Environmental Engineer, Air Quality Bonanza Creek Energy 410 17th Street, Suite 1400 Denver, CO 80202 Office 303-803-1752 Cell 720-315-0691 Fax 720-305-0804 asoehner@bonanzacrk corn ti wwwbonanzacrk corn S4 sannn I CREEK J CONFIDENTIALITY NOTICE This e-mail transmission, and any documents, files or previous e-mail messages attached to it, may contain information that is confidential or legally privileged Any unauthorized review, use, disclosure or distribution of such information is prohibited If you are not the intended recipient, please notify the sender by telephone or return e-mail and permanently delete the original transmission and its attachments and destroy any copies thereof Thank you From Patrick Dilsaver [mailto pd►lsaver@slrconsulting corn] Sent Tuesday, March 12, 2019 3 30 PM To Fischbach - CDPHE, Ben <ben fischbach@state co us> https //mail google com/mail/u/0'2ik=0ddlcdaf99&view=pt&search=all&permthid=thread-f%3A1624737411799893199&simpl=msg-f%3A16247374117 8/12 3/26/2019 State.co.us Executive Branch Mail - Mustang Y-34 Permit Application Redline Additionally, it was brought to my attention that the incorrect heating value was used in this application (2,452 BTU/scf instead of 2,661 BTU/scf). Combustion emissions calculations should be based on the HHV of the gas rather than the LHV, as the equations of AP -42 were written based on HHV. Please let me know if you agree with my assessments above (in which case I'll redline the APEN with these changes) or if you would like to discuss. Thanks! Ben [Quoted text hidden] Patrick Dilsaver <pdilsaver@slrconsulting.com> To: "Fischbach - CDPHE, Ben" <ben.fischbach@state.co.us> Cc: Alisson Soehner <asoehner@bonanzacrk.com>, EHSRC <EHSRC@bonanzacrk.com> Tue, Mar 12, 2019 at 3:30 PM Hey Ben, We agree with your calculations, I think we had mistakenly referenced the flow INTO the tanks so it was off there. We also agree to use the HHV value of 2,661 instead of the LHV value. Let me know if you need anything further from me, thanks!--_ _ [Quoted text hidden] Fischbach - CDPHE, Ben <ben.fischbach@state.co.us> Fri, Mar 15, 2019 at 8:58 AM To: Patrick Dilsaver <pdissaver@slrconsulting.com> Hey Pat, I made the redlines that we discussed and attached the P,PEN to this email for your review. I also want to ask about the flare(s) on this permit to make sure that I include the right conditions given the requested 98% destruction efficiency. The PFD seems to indicate that the three permitted points share a single common flare - is this the actual configuration or are there more than one in use at this site? Thanks! Ben [Quoted text hidden] eras�axawa�csr.re�.z�»-x-ca 123-9FF4-001 Redlines.pdf 1.1 2515K Alisson Soehner <ASoehner@bonanzacrk.com> Wed, Mar 20, 2019 at 12:46 PM To: Patrick Dilsaver <pdilsaver@slrconsulting.com>, "Fischaach - CDPHE, Ben" <ben.fischbach@state.co.us> Cc: EHSRC <EHSRC@bonanzacrk.com> Hi Ben — I am wondering you could please tell me the status of this permit? https://mail.google.com/mail/u/0?ik=Odd 1 cdaf99&view=pt&search=all&perrnthid=thread-f%3A1624737411799893199&simpl=msg-f%3A16247374117... 7/12 Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit RECEIVED SEP 1 8 2019 APCD 5tattutiar7 Sofgee All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/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: Be` 181�1C 102 AIRSID IQ1 , / Number: � 23 rr er [Leave blank unless APCD has already assigned a permit A and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Bonanza Creek Energy Operating Company, LLC Mustang Y-34 Production Facility (C0GCC# 450213) Site Location: SESE S34 T4N R63W 40.262061, -104.416133 Mailing Address: (Intrude Zip Code) 410 17th Street, Suite 1400 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address2: Alisson Soehner (303) 803-1752 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. Form APCD-2O7 - Produced Water Storage Tank(s) APEN - Revision 7/2018 387843 NINg COLORADO 1 I Lei . • =c7==., Permit Number: TBD AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 2 - Requested Action Q NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP05 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership' ❑ 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 It Notes: Initial E&P wellsite application 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. ' For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Storage of produced water prior to being trucked out PWT-01 For new or reconstructed sources, the projected start-up date is: 06/20/2018 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 weeks/year ❑✓ Exploration Et Production (E&P) site ❑ Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? ✓ Yes ❑ No Are Flash Emissions anticipated from these storage tanks? ✓ Yes ❑ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? ❑ Yes No ✓ Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ❑ Yes i No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. ❑ Yes No ✓ Are you requesting a 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? ❑ Yes No ✓ Form APCD-207 - Produced Water Storage Tank(sl APEN - Revision 7/2018 2 A. COLORADO L:FY s:o[I+it=c Permit Number: TBD AIRS ID Number: 123 I [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 4 - Storage Tank(s) Information Produced Water Throughput: Actual Annual Amount (bbl/year) 124,100 Requested Annual Permit Limits (bbl /year) 148,920 From what year is the actual annual amount? Tank design: ❑✓ Fixed roof ❑ Internal floating roof ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) PWT-01 (1) 500 -bbl 500 06/2018 06/2018 Wells Serviced by this Storage Tank or Tank Battery6 (EEtP Sites On y) API Number Name of Well Newly Reported Well 05 - 123 - 44702 Longhorn V41-3-4XRLNB ✓ 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EEtP 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) 40.262061, -104.416133 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) ECD-01 35 Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Downward ❑ Horizontal ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): ❑ Square/rectangle Interior stack width (inches): ❑ Other (describe): ❑ Upward with obstructing raincap 96 Interior stack depth (inches): COLORADO Form APCD-2O7 - Produced Water Storage Tank(s) APEN - Revision 7/2018 3 �4. Permit Number: TBD AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit if and MRS 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. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): % ❑ Combustion Device: Pollutants Controlled: VOC, HAP Rating: 4 MMBtu/hr Type: Enclosed Combustor Make/Model: Crimson CE 1000 Requested Control Efficiency: -95- 98 Manufacturer Guaranteed Control Efficiency: Minimum Temperature: N/A 98 % gF /`2.0-c1l c VI-. cLe Waste Gas Heat Content: 2,452 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: N/A MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (EftP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 75 psig Describe the separation process between the well and the storage tanks: The well produces to a single stage 3 -phase separator where produced water is separated out and routed to the produced water tank. Form APCD-2O7 - Produced Water Storage Tank(s) APEN - Revision 7/2018 4 I Ail COLORADO Permit Number: TBD AIRS ID Number: 123 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] 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): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECD -95-- is NOX CO HAPs ECD •95- IS Other: From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions8 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 0.2620 lb/bbl State EF 16.26 -0781-0..; 19.51 -698-0, 9 NOx 0.00090.0U ` State EF N/A 0.8G D, z N/A s-e�0, 3 co 0.002 o• 3 � ►ft State EF N/A $-1.5 I.0 N/A 0.18 I.Z p . 2 / 70611 `l . Per 4"P+4 d3 F, 2 /2a/ I'1 Per et+-fr., ej eM / Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mf etc.) Mfg., Uncontrolled Emissions (pounds/year) (pounds/ ear Controlled Emissions8 (pounds/ year) Benzene 71432 0.0070 lb/bbl State EF 870 -.44- 13 - Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0220 lb/bbl State EF 2,732 4-3$ S c 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 - Produced Water Storage Tank(s) APEN Revision 7/2018 COLORADO 5 I 116Y Permit Number: TBD AIRS ID Number: 123 I / [Leave blank unless APCD has already assigned a permit ?, and MRS ID] 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 GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signature of Legally Authorized Person (not a vendor or consultant) Alisson Soehner Date Environmental Engineer, Air Quality Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.cotorado.gov/cdphe/aped COLORADO Form APCD-2O7 - Produced Water Storage Tank(s) APEN - Revision 7/2018 3/26/2019 State.co.us Executive Branch Mail - Mustang Y-34 Permit Application Redline We have no problem with going to the higher control % for all sources, but don't think it's necessary in this case.. [Quoted text hidden] Fischbach - CDPHE, Ben <ben.fischbach@state.co.us> Tue, Mar 26, 2019 at 2:51 PM To: Patrick Dilsaver <pdilsaver@slrconsulting.com> No worries, I just wanted to ask in case there was anything I was missing. I'll go ahead and redline the APENs for the points 002 (Produced Water Tanks) and 004 (Loadout) to reflect a requested flare efficiency of 98% for each. Thanks! Ben [Quoted text hidden] https://mail.google.com/mail/u/0?ik=0dd 1 cdaf99&view=pt&search=all&permth id=thread-f%3A1624737411799893199&simpl=msg-f%3A1624737411... 12!12 3/26/2019 State.co.us Executive Branch Mail - Mustang Y-34 Permit Application Redline Let me know if you need anything else! Pat From: Fischbach - CDPHE, Ben[mailto:ben.fischbach@state.co.us] Sent: February 15, 2019 1:30 PM To: Patrick Dilsaver Subject: Re: Mustang Y-34 Permit Application Redline Hey Pat, I came across a few issues and questions regarding the application package for the Mustang Y-34 Procuction facility. Regarding the produced water tanks, we have stopped accepting the NOx and CO emission factors from the "Condensate Flare Emission Factors" internal memo from 3/22/2005. Instead, the emission factors given in chapter 13.5 of AP 42 are now the most commonly used (0.068 Ib/MMBtu for NOx and 0.31 Ib/MMBtu for CO). Using these emission factors (as well as the GOR and heat content given for produced water tanks in PS Memo 14-03) the annual requested permit limits for NOx and CO would become 0.3 tpy and 1.2 tpy respectively. We agree with these calculations and can redline the APEN if needed. The gas venting calculations sheet indicates that the emission factors were calculated based on the weighted average sales gas analysis, but excludes several of the less -relevant constituents (ethane, propane, etc.). Our spreadsheet takes these into account when calculating the emission factors - could you please send the full list of components with their corresponding weighted averages? We actually just used one sample, looks like that footnote wasn't updated. The attached sample (excel sheet) has all of the constituents and I included the pdf sheet that was in the original application showing we just used the one sample to get the emission factors. Let me know if this is what you needed. Finally, I noticed that 98% control efficiencies were requested for the condensate tank battery and gas venting APENs. I just wanted to bring to your attention that, while I can permit these points with 98% efficiency, the permit would contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling. Thank you we are aware of this permit condition and are prepared to do the required testing for this unit. [Quoted text hidden] [Quoted text hidden] ::4cc-t 5-1.-s rs=2;7M**:%-::7••:r9Kfl ?a".':iC'.'.s.,".S'i3W�1G."ArzsirRXs".COY:ameA.R %5 tales wzrzt'A`C'X:ivzmMP.Y5'.`•xxs c'. vaszS'.ibwsasost ;7N:Sf�ci�.::Y>.a,Zo�rYgR? f".M 2 attachments r_I Mustang U-22 Raw NGA_X.xlsx 55K Gas Analysis Sheet.pdf 114K Fischbach - CDPHE, Ben <ben.fischbach@state.co.us> Wed, Feb 20, 2019 at 2:18 PM To: Patrick Dilsaver <pdilsaver@slrconsulting.com> Hey Pat, https://mail.google.com/mail/u/0?ik=0ddl cdaf99&view=pt&search=all&permth id=thread-f%3A1624737411799893199&simpl=msg-f%3A16247374117... 4/12 3oearseJeJ — (et A 4 61, e& AA W/' Add frari-, �ved b2/06/Z©I Gas Venting APEN - Form APCD-211 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. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). h 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) websiite at: www.colorado.gov/cdphe/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: TSB,. 1ZIElo2,2-• AIRS ID Number: [Leave blank unless APCD has already assigned a permit A and AIRS ID] 123 /CI FF4. 003 Section 1 - Administrative Information Company Name: Bonanza Creek Energy Operating Company, LLC Site Name: Mustang Y-34 Production Facility (C0GCC# 450213) Site Location: SESE S34 T4N R63W 40.262061, -104.416133 Mailing Address: 410 17th Street, Suite 1400 (Include Zip Code) Denver, CO 80202 Site Location County: Weld RECErvED SEP 1 B 2018 NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address2: Alisson Soehner (303) 803-1752 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. Form APCD-211 - Gas Venting APEN - Revision 7/2018 387845 1 ( AV COLORADO A?CD Swim-wry Soure0 Permit Number: TBD AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit rt and AIRS ID] Section 2 - Requested Action • NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ 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 - Li Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Er Notes: Initial E&P wellsite application. No Pipeline Infrastructure available at this time; produced gas is flared at the Crimson ECD. 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: Produced gas venting will be controlled at an ECD - Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 6/20/2018 ❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: 24 Will this equipment be operated in any NAAQS nonattainment area? hours/day 7 Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-211 - Gas Venting APEN - Revision 7/2018 days/week 52 weeks/year Q Yes ❑ Yes 0 Yes ❑ No O No ❑ No Nf„COLORACIO 2 I C.,,anmmr. nt Pity: Permit Number: TBD AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit ,t and AIRS ID] Section 4 - Process Equipment Information 0 Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: # of Pistons: Volume per event: Capacity: gal/min Leak Rate: Scf/hr/pist MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes Gas Venting_— — Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ No Vent Gas Heating Value: 1 590 - , Requested: 110 MMSCF/year Actual: N/A MMSCF/year -OR-- Requested: bbl/year Actual: bbl/year Molecular Weight: VOC (Weight %) 45.6323 Benzene (Weight %) 0.1747 Toluene (Weight %) 0.2157 Ethyibenzene (Weight %) 0.0376 Xylene (Weight %) 0.1299 n -Hexane (Weight %) 1.2620 2,2,4-Trimethylpentane (Weight %) 0.0009 Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX a n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX >:t n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 3 { A Form APCD-211 - Gas Venting APEN - Revision 7/2018 COLORADO 1,42..nm Permit Number: TBD AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit ft and AIRS ID) Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.262061, -104.416133 Operator s Stack ID No. Discharge ; Height Above Ground Level ` (Feet) Temp. F (' ) ' Flow Rate ACFM ( ) Velocity (f t/sec) ECD-01 35 Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) 0 Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap 96 = 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. ❑ VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: % % ❑ Combustion Device: Pollutants Controlled: VOC, HAP Rating: 20 Type: Enclosed Combustor MMBtu/hr Make/Model: Crimson CE 1000 Requested Control Efficiency: 98 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Waste Gas Heat Content: 1,590 Btu/scf Constant Pilot Light: ❑✓ Yes O No Pilot burner Rating:. N/A MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 7/2018 4I A COLORADO is 'rr Farv,4ftm, 4 Permit Number: TBD AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] 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): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOx NO. CO VOC ECD 98 HAPs ECD 98 Other: From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units source (AP -42, Mfg., etc.) Uncontrolled- Emissions (tons/year) — Controlled Emissions6 (tons/year) Uncontrolled Emissions (tons/year) -_- Controlled Emissions (tons/year) PM SOx 0.00005 lb/MMBtu AP -42 N/A N/A N/A 0.01 NO. 0.068 lb/MMBtu AP -42 N/A N/A N/A 5.93 CO 0.310 lb/MMBtu AP -42 N/A N/A N/A 27.00 VOC 33,556 lb/MMscf Mass Balance N/A N/A 1,837 36.75 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Sasis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions6 (pounds/year) Benzene 71432 128.5 Ib/MMscf Mass Balance 14067.10 281.34 Toluene 108883 158.6 lb/MMscf Mass Balance 17368.49 347.37 Ethylbenzene 100414 27.6 lb/MMscf Mass Balance 3027.60 60.55 Xylene 1330207 90.4 lb/MMscf Mass Balance 9896.08 197.92 n -Hexane 110543 928.0 lb/MMscf Mass Balance 101618.14 2032.36 2,2,4- Trimethylpentane 540841 0.7 Ib/MMscf Mass Balance 72.47 1.45 Other: 5 Requested values will become permit limitations. Requested timit(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. Form APCD-211 - Gas Venting APEN - Revision 7/2018 51 COLORADO Haat II, h Fr: r now Permit Number: TBD AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit # and AIRS D] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. oekc, Signature of Legally Authorized Person (not a vendor or consultant) Date Alisson Soehner Environmental Engineer, Air Quality Name (please print) Title Check the appropriate box to request a copy of the: O Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 6 I �I nl COLORADO 2/6/2019 State.co.us Executive Branch Mail - Mustang Y-34 Permit Application Redline STATE OF COLORADO Fischbach - CDPHE, Ben <ben.fischbach@state.co.us> Mustang Y-34 Permit Application Redline 2 messages Patrick Dilsaver <pdilsaver@slrconsulting.com> Wed, Feb 6, 2019 at 9:25 AM To: Alisson Soehner <asoehner@bonanzacrk.com>, "Fischbach - CDPHE, Ben" <ben.fischbach@state.co.us> Cc: EHSRC <EHSRC@bonanzacrk.com> Ben, We just got notice that you had been assigned the Mustang Y-34 Permit Application package. We have a redline for the Gas Venting APEN that is attached. Could you process this in place of the APEN that was submitted? Thank You, Pat SLR Patrick Dilsaver Project Scientist o 307-214-9584 970-494-0805 O - pdilsaver@slrconsulting.com SLR International Corporation 1612 Specht Point Road, Suite 119, Fort Collins, CO, 80525 l iVIVERS Intemoti;onalRusix css EncdknceA4 rrd,2O16 Confidentiality Notice and Disclaimer https://mail.google.com/mail/u/0?ik=0dd 1 cdaf99&view=pt&search=all&permthid=thread-f%3A1624737411799893199&simpl=msg-f%3A162473741179... 1/2 2/6/2019 State.co.us Executive Branch Mail - Mustang Y-34 Permit Application Redline This communication and any attachment(s) contain information which isconfidential 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. CAM BXIS Mustang Y-34_REDLINE_20'180920.pdf 405K Fischbach - CDPHE, Ben <ben.fischbach@state.co.us> Wed, Feb 6, 2019 at 10:40 AM To: Patrick Dilsaver <pdilsaver@slrconsulting.com> Hi Pat, That sounds good, thanks for getting this to me so quickly. I would also like to verify where the gas and pressurized liquid samples were drawn from for this application - were the samples both taken from the production separator outlets? Thanks, Ben [Quoted text hidden] Ben Fischbach Oil ft Gas Permitting Engineer Stationary Sources Program COLORADO - Aix Pollution Control Division Department of Public Health & Environment Colorado Department of Public Health a Environment P 303.692.2108 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246-1530 ben.fischbach@state.co.us I www.colorado.gov/apcd https://mail.google.com/mail/u/0?ik=0dd1 cdaf99&view=pt&search=all&permthid=thread-f%3A1624737411799893199&simpl=msg-f%3A162473741179... 2/2 ce+i )./024}41 t. Gas Venting APEN — Form APCD-211 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. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, welt head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/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: —T43.13 1 tJ Icy22 [Leave blank unless APCD has already assigned a permit # and AIRS ID] AIRS ID Number: 123 /9 F F� 003 Section 1 —Administrative Information Company Name: Bonanza Creek Energy Operating Company, LLC Site Name: Mustang Y-34 Production Facility (C0GCC# 450213) Site Location: SESE S34 T4N R63W Mailing Address: 40.262061, -104.416133 (Include Zip Code) 410 17th Street, Suite 1400 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 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 nvoices will be issued by the APCD via e-mail to the address provided. COLORADO Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 I AT � " °'"""` b Elwi:m�me. 1 Permit Number: TBD AIRS ID Number: 123 I / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 O Other (describe below) OR O 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 It Notes: Initial E&P wellsite application. No Pipeline Infrastructure available at this time; produced gas is flared at the Crimson ECD. 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 e- Producedgas venting will be controlled at an ECD General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 6/20/2018 ❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: 24 Will this equipment be operated in any NAAQS nonattainment area? hours/day 7 Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-211 - Gas Venting APEN - Revision 7/2018 days/week 52 weeks/year 0 Yes ❑ No ❑ Yes 0 No O Yes ❑ No COLORADO 2 I ®' _ m----� Permit Number: TBD AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ▪ Gas/Liquid Separator O Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: # of Pistons: Volume per event: Capacity: gal/min Leak Rate: Scf/hr/pist MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ET Yes Gas Venting - Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: [] No Vent Gas Heating Value. , 590 BTU/SCF__ _ Requested: 110 180.0 MMSCF/year Actual: N/A MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: VOC (Weight %) 45.6323 Benzene (Weight %) 0.1747 Toluene (Weight %) 0.2157 Ethylbenzene (Weight %) 0.0376 Xylene (Weight %) 0.1299 n -Hexane (Weight %) 1.2620 2,2,4-Trimethylpentane (Weight %) 0.0009 Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX a n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX a n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 7/2018 pp COLORADO 3 I Al.T...,1,17:1 Hcpatlh6EnvVotma+l Permit Number: TBD AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.262061, -104.416133 Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. ("F) Flow Rate (ACFM) Velocity (ft/sec) ECD-01 35 Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular O Other (describe): Interior stack diameter (inches): O Upward with obstructing raincap 96 Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: ❑✓ Combustion Device: Pollutants Controlled: VOC, HAP Rating: 20 33 MMBtu/hr Type: Enclosed Combustor Make/Model: Requested Control Efficiency: 98 Manufacturer Guaranteed Control Efficiency: 98 Crimson CE 1000 Minimum Temperature: N/A Waste Gas Heat Content: ,590 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: N/A MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 7/2018 4IACOLORADO . =.. Permit Number: TBD AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] 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 ontrol efficiency reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO. CO VOC ECD 98 HAPs ECD 98 Other: From what year is the following reported actual annual emissions data? CriteriaPollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Source (AP -42, Mfg., etc.) Mfg., Uncontrolled Emissions ' (tons/year) Controlled Emissions (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SOx 0.00005 lb/MMBtu AP -42 N/A N/A N/A 0.01 NO. 0.068 lb/MMBtu AP -42 N/A N/A N/A 5.03 CO 0.310 lb/MMBtu AP -42 N/A N/A N/A 27.00 VOC 33,556 lb/MMscf Mass Balance N/A N/A 1,837 3,020 5 36.75 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Service (CAS) Number Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) - Controlled Emissions 6 (pounds/year) Benzene 71432 128.5 lb/MMscf Mass Balance 11067.1023 126.0 281.31 464.0 Toluene 108883 158.6 lb/MMscf Mass Balance 17368.49 28,552.0 317.37 572.0 Ethylbenzene 100414 27.6 lb/MMscf Mass Balance 3027.604,978.0 60.55 100.0 Xylene 1330207 90.4 lb/MMscf Mass Balance 9896.08 16,268.0 197.02 326.0 n -Hexane 110543 928.0 lb/MMscf Mass Balance 101618.14167,044.0 2032.36 3 342.( 2'2'4- Trimethylpentane 540841 0.7 lb/MMscf Mass Balance 72.47120.0 1.45 4 0 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. 9.74 44.38 60.41 Form APCD-211 - Gas Venting APEN - Revision 7/2018 COLORADO 5 I Ay ntdad HtaHrt _ Em an.rne \I Permit Number: TBD AIRS ID Number: 123 A / =.._i ni_r,' pc nut MRS ,13] Section 8 - Applicant Certification i hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. Getk4)-?_. Signature of Legally Authorized Person (not a vendor or consultant) Alisson Soehner Date Environmental Engineer, Air Quality Name (please print) Title Check the appropriate box to request a copy of the: O Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxesmay 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 (signi€icant 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: Colorado Department of Public stealth and Environment Air Pollution Control Division APCD-SS-B9 4300 Cherry Creek Drive South Denver, CO &0246.153D Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call.: Small Business Assistance Program (303) 692.3175 or (303} 692.3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: r Iwww,colorado.eov/cdphe/aped Form APCD-211 Gas Verd:ir.g APEN - Re: iatarr 7.'"201 Y COLORADO - 6 1 m�,�-:,.,:nom-,� AMP Yer-..:.�.� Hello