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Home My WebLink About20190092.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 December 18, 2018 Dear Sir or Madam: RECEIVED DEC 21 2018 WELD COUNTY COMMISSIONERS On December 20, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Bonanza Creek EOC, LLC - Crow Valley 7-62-34-2H Ft 27-2H. 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, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure ?LAIC Q�.i‘ea,J 1/ 2/ Ic1 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer CC.PLCTP),NLLIT), ?WCzw1 I ERICA ICV\ 1.121/%2, 2019-0092 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Bonanza Creek EOC, LLC - Crow Valley 7-62-34-2H Et 27-2H - Weld County Notice Period Begins: December 20, 2018 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 EOC, LLC Facility: Crow Valley 7-62-34-2H a 27-2H Oil and gas exploration and production facility NENW Sec 34 T7N R62W Weld County The proposed project or activity is as follows: Source is requesting to increase the amount of produced gas routed to flare from 6 Mmscf/yr to 16.2 MMscf/yr The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 15WE0705 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. Any such comment must be submitted in writing to the following addressee: Carissa Money Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us 1 OLORADO Permit number: Date issued: Issued to: COLORADO Air Pollution Control Division Department of Public Health & Environment CONSTRUCTION PERMIT 1 5WE0705 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 4 Bonanza Creek Energy Operating Company, LLC Crow Valley 7-62-34-2H £t 27-2H Production Facility 123/9A4C NENW SEC 34 T7N R62W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TL 005 Hydrocarbon loadout to tanker trucks None EFLR-01 007 Venting of produced natural gas from two (2) two-phase inlet separators and two (2) heater treaters (3 -phase separators) during pipeline downtime 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 this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self -certify. (Regulation Number 3, Part B, Section III.G.5.) EMISSION LIMITATIONS AND RECORDS 2. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) ) COLORADO Air Pollution. Control D is on Page 1 of 8 Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO TL 005 1.8 Point EFLR-01 007 --- --- 11.2 3.7 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to catculate limits. 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. 3. 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 EFLR-01 007 Enclosed Flare (Cimarron 48") VOC and HAP PROCESS LIMITATIONS AND RECORDS 4. 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 TL 005 Condensate loaded 24,364 BBL EFLR-01 007 Gas vented from Inlet Separators and Heater Treaters during pipeline downtime 16.2 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. 5. Point 007: The owner or operator shall continuously monitor and record the volumetric flow rate of gas vented from the separator(s) and heater treaters to the flare using the flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 6. 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) 7. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment Page 2 of 8 visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. a 4.) 8. Point 007: No owner or operator of a smokeless flare or other flare for the combustion of waste. gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 9. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 10. Point 005: This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) 11. Point 005: The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.E): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. The owner or operator shall inspect loading equipment and operations on site at the time of the inspection to ensure compliance with the conditions above. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 12. Point 005: All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. OPERATING Et MAINTENANCE REQUIREMENTS 13. Point 007: Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (0&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING 14. This source is not required to comply with any testing and sampling requirements. ADDITIONAL REQUIREMENTS 15. All previous versions of this permit are cancelled upon issuance of this permit. 16. 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: 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 COLORADO Air Pollution. Control Division AYiY'f4nt Nasttt HPld8t SJ F.rtV t Page 3 of 8 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. 17. 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 18. 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. 19. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 20. 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. 21. 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. 22. 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 'COLORADO M PoUui€oi Control Division Lmt'ar at ^,`. Pt r .5'""..TCrnWet Page 4 of 8 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. 23. 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. 24. 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: Carissa Money Permit Engineer Permit History Issuance Date Description Issuance 1 September 17, 2015 Issued to Bonanza Creek Energy Operating Company, LLC for loadout and venting of gas from separator to flare during pipeline downtime Point 005 was previously on Permit No. 13WE1171.XP Issuance 2 September 22, 2016 Issued to Bonanza Creek Energy Operating Company, LLC Increase limits for AIRS 007 and update emissions based on recent sample. Replace enclosed flare with open flare. Issued as Final Approval. Issuance 3 April 12, 2017 Issued to Bonanza Creek Energy Operating Company, LLC Modified emission controls on Point 007 to use existing enclosed combustor, instead of open flare. Issued as Final Approval. Issuance 4 This issuance For Point 007, increase requested throughput from 6 MMscf to 16.2 MMscf/yr and increase requested VOC limit from 4.4 to 11.2 tpy. Issued as Final Approval. COLORADO Air Psxitution 00.1,40A Division L r: int"31 FL .3W af2hEt IrAtrr`:7 §st Page 5 of 8 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 listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) TL 005 Benzene 71432 13 13 n -Hexane 110543 77 77 Toluene 108883 32 32 Xylenes 1330207 26 26 EFLR-01 007 Benzene 71432 1,769 88 Toluene 108883 964 48 Ethylbenzene 100414 130 7 Xylenes 1330207 427 21 n -Hexane 110543 11,940 597 2,2,4- Trimethylpentane 540841 1,588 79 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 005: Pollutant Emission Factors - Uncontrolled Ib/BBL loaded Source V0C 0.1462 AP -42 Benzene 0.0005 AP -42 COLORADO Air Pottution. Control Division Page 6 of 8 Pollutant Emission Factors - Uncontrolled lb/BBL loaded Source n -Hexane 0.0032 AP -42 The uncontrolled V0C emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 6.4 psia M (vapor molecular weight) = 38.3 lb/lb-mol T (temperature of liquid loaded) = 524 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the sales oil by the V0C emission factor. Point 007: CAS # Pollutant Weight Percent of Gas (%) Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source N0x --- 100.57 100.57 AP -42, Table 13.5-1 CO --- 458.49 458.49 AP -42, Table 13.5-2 V0C 39.78 27,578 1,378.9 Extended gas analysis 71432 Benzene 0.158 109.19 5.4596 Extended gas analysis 108883 Toluene 0.086 59.484 2.9742 Extended gas analysis 100414 Ethylbenzene 0.012 8.0421 0.4021 Extended gas analysis 1330207 Xylene 0.038 26.345 1.3172 Extended gas analysis 110543 n -Hexane 1.063 737.03 36.852 Extended gas analysis 540841 2,2,4- Trimethylpentane 0.141 98.031 4.9015 Extended gas analysis Note: The uncontrolled V0C and HAP emissions for this point were calculated using the 10/23/2015 analysis of a sales gas sample collected from the Crow Valley 7-62-34-2H well. The controlled V0C and HAP emissions factors are based on the flare control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN 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 facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: V0C OLORA O Air Pollution Control Division 'C,uYu 9l Ft€ it 3 36K'3 a Er4-4 n'^^. m Page 7 of 8 NANSR Synthetic Minor Source of: V0C 8) Fulltextof 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 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 MM/vVAM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Aix Pollution Control Division Page 8 of 8 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: EarissaMoney Packaged: 385407; Received Date: 17/15/2018 Review Start Date: 12(4%2013., Section 01 - Facility Information Company Name: Bonanza Creek Energy Operating Company, LLC County AIRS ID: 125 Plant AIRS ID: Facility Name: Physical Address/Location: NENW quadrant of Section 34, Township 7N, Range 62W County: Type of Facility: Etploiatian &;Ptxzds Iron wql Pam' What industry segment?Olt&{f'ti*y),a3spuducti :'Pracssing.::. Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? Er Carbon Monoxide (CO) Section 02.- Emissions Units In Permit Application Weld County Quadrant Section Township Range Particulate Matter (PM) [] Ozone (NOx & VOC) AIRs Point d Emissions Source Type Equipment Name Emissions Control? Permit it Issuance It Self Cert Required? Action Engineering Remarks 007 15W80705 ,, increasing ` throughput and emissions Section 03 - Description of Project Bootee is requesting to increase flaring of natural gas'duting pipeline downtime The scarce"is requestingto increase from',nffifsor/yr routed to' -Flare to ib.� MMscf/yr which increases VOC limit from 44 toy to 11.2 toy, The last two issuances of this permit were Issued as Final Approval. Even though, With this modification, this site:is now becoMing synthetic minor instead of true minor, I will still issue the permit as a tin 14 pr val The flare and separator are existing equipment and there is no change in.regulatary applicability or testing, so no self -certification requirements are needed. The division does riot typically include short-term limits for E&P sites so the permitt will Mat include tS.- .. - _ ._. , , .. i Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesi-?ngSyrsthetic Mine r Per Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? 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 (PSD) 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 SO2 S02 NOx CO VOC PM2.5 PM10 TSP HAPs NOx 1. I LI CO VOC PM2.5 PM10 TSP HAPs Colorado Air Permitting Project Prevention of Significant Deterioration (PSD) - Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR). L 1 ❑ Separator Venting Emissions Inventory 007 Separator Venting Facility AIRs ID: Coun Plant Poin Section 02 - Equipment Description Details Detailed Emissions Unit Description: 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= ESINTSMER MMscf per year Requested Permit Limit Throughput = , 1&.21MMscf peryear . Requested Monthly Throughput= MMscf per month Potential to Emit (PIE) Throughput = Process Control (Recycling) Equipped with a VRU:?. Is VRU process equipment: 16 MMscf per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Valum Volume of waste gas emitted per Bui liquids throughput: Section 04 - Emissions Factors & Methodologies k79` Btu/scf ___.......... Weight % Helium CO2 N2 methane ethane propane isobutane n-hutane isopentane n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224-TMP Benzene Toluene Ethylbenzene Xylenes C8+ Heavies <7541 2-4421 s4� ... .._ 0:1'414 Total VOC Wt % 100.00 39.78 scf/bhl Ib/Ib-mol Displacement Equation Ex=Q*MW * Xx / C Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/MMscf) (lb/MMscf) (Gas Throughput) VOC 27578 109.19 59.484 8.0421 26,345 737.03 98.031 Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Pollutant (Gas Throughput) Emission Factor Source 5.4596 2.9742 0.4021 1.3172 36.852 4.9015 Primary Control Device Uncontrolled lb/MMscf Uncontrolled (Ib/MMBtu) (Waste Heat Combusted) (Gas Throughput) Emission Factor Source PM10 PM2.5 SOx NOx CO 11.020 11.020 0.870 100.572 458-490 3 of 6 K:\PA\2015\15 W E0705.CP4,xlsm 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 (Ibs/month) PNt10 PM2.5 SOx. NOx VOC CO - 0,09 - 0:00 0.00 - 0.09 0.09 15 0.09 0.00 0.00 0.09 0.09 15 0.01 0.00 0.00 0.01 0.01 1. 0.81 0.00 0.00 0:81 0.81 138 223.38 0,00 - 0.00 223.38 11.17 1897 3.71 :0.00 0,00 3.71 5.71 631. Hazardous Air Pollutants - - - - Potential to Emit Uncontrolled (lbs/year) Actual Emissions -Uncontrolled- Controlled (Ibs/year) (Ibs/year) Requested Permit Limits. Uncontrolled Controlled (Ibs/year) (lbs/year)- - ' Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP - 1759'. 0 0 1769' 88 954: 0 0 964 - -48'- 130 0- 0 130 7 427 0 0 427 21 11940 0 0.-. 11940 597 1588 0 0 1583 79 Section 06- Regulatory Summary Analysis. Regulation 3, Parts A, B Regulation 7, Section XVII.0, G Regulation 7, Section.XVII.B.2.e (See regulatory applicability worksheet for detailed analysis). Source requires a permit Source is not subject to Regulation 7, Section XVII.B.2, G The control device for this separator is not subject to Regulation 7, Section XVII.8.2.e Section 07 -Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on agassample 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 an -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 sample from the equipment being permitted andconduct an emission factor analysis to demonstrate that the .emission : factors are less than or equal to the emissions factors: established with this application. Are facility -wide permitted emissions of VOC greater than or equal: to 90 tons per year? If yes, the permit will contain: - -An "Initial Testing Requirement" to: collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. ' -A "Periodic Testing Requirement" to collect asite-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter isinstalled and operational (not: to exceed 180 days). This condition will use the "Volume of wastegas emitted per BBL of liquidsthroughput" (scf/bbi( 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 destraction 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 d 4 of 6 - K:\PA\2015\15WE0705.CP4.xlsm Separator Venting Emissions Inventory Section 08 - Technica4Analvsis Notes Source is basing emissions on the some site -specific gds sample used for all prior issuances of this permit:Since the peHnithas nut regnired nn gaingsampCitng of the gas, I will accgpithe., Factors In the permit to match the factors in this PA. With the Increased ₹hroughput, the facility and point are now syntheticminor so the permit rrius€go through public comment. - AIRS Point# Process # SCC Code 007 01 / 3-10-001-60 Flares Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions Pollutant -- Factor Control % Units PM10 11:02 0 lb/MMSCFPM2.5 11.02'. 0 lb/MMSCF SOx 0.87 0 ' lb/MMSCF NOx 100.57 0 lb/MMSCF VOC 27577.73 95 lb/MMSCF CO - 458.49 0 Ib/MMSCF Benzene 109.19 95. lb/MMSCF Toluene 59.48 95 Ib/MMSCF Ethylbenzene 8.04 95 lb/MMSCF Xylene 26.34 95 lb/MMSCF n -Hexane 737.03 95 - lb/MMSCF 224 IMP 98.03 95 lb/MMSCF 5 of 6 - - K:\PA\2015\15WE0705.CP4.xlsm Separator Venting Regulatory Analysis Worksheet 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.l.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than lOTPY (Regulation 3, Part B,5ectien 11.0.3)? 'Not enough Information NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than (TPY (Regulation3, Part A, Section ll.0.1.a(? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than STPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)7 'Source requires a permit Colorado Regulation 7, Section XVII I. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? 'Source Is not subject to Regulation 7, Section XVIl.B.2, G section XVII.B.2— General Provisions for Air Pollution -Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emlesiors Control (OptionalSealant Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? 'The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e Section XVII.B.2.e—Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clears 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 otherlegally 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. Theuse 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 theterms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. 1e§;Ite';Source Req Source is m The control ©©\py Air Pollutant Emission Notice (APEN) and Application for Construction Permit Natural Gas Venting APEN - Form APCD-211 RECEIVED. JUL 18 2018 APCD c+ ;onar} 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 Natural Gas Venting only. Natural 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. 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: 15WE0705 13 Company equipment Identification: EFLR-1 AIRS ID Number: 123n/ 9A4C/ 007© Section 1 - Administrative Information Company Name: Bonanza Creek Energy Operating Company, LLC Site Name: Crow Valley 7-62-34-2H & 27-2H (COGCC#428002) Site Location: NE/NW Sec. 34, T7N, R62W Mailing Address: (Include Zip Code) 410 17th Street, Suite 1400 Denver, CO 80202 E -Mail Address'-: asoehner@bonanzacrk.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Alisson Soehner Phone Number: (303) 803-1752 'Please 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 APCD via e-mail to the address provided. Form APCD-211 Nal:li t Gas Venting(APEN Rev 03/2017 385406 ®V coLoaaoo 1 Permit Number: 15WE0705 13 AIRS ID Number: 123▪ i9A4C / 007© and iARS1.1)1 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 name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) - OR APEN submittal for update only (Please 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 a Notes: Increase requested produced gas flaring volume 3 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: Vented Gas from two (2) inlet separators and two (2) heater treaters during pipeline downtime/upset events. Controlled by ECDs. For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 7 / 17 / 2012 / / ✓❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions days/week weeks/year ❑✓ Yes ❑ No ❑ Yes ❑✓ No Form f PCD-211 N: +ur l; Gas v. n info ^,PEr': Rev 03/2017 2 I A COLORADO Permit Number: 15WE0705 13 AIRS ID Number: ll �A 123▪ /9A4C/ 007© t; Section 4 - Process Equipment Information ❑r Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: Gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? LI Yes Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑ No Maximum Vent Rate: 1,849'3 SCF/hr Vent Gas Heating Value: BTU/SCF Requested: 16.2 MMSCF/year Actual: MMSCF/year -OR- Requested: Bbl/yr Actual: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: 26.2756 Ib/Ib-mol VOC (mole %) 18.93 VOC (Weight %) 39.79 Benzene (mole %) 0.053 Benzene (Weight %) 0.157 Toluene (mole %) 0.025 Toluene (Weight %) 0.086 Ethylbenzene (mole %) 0.003 Ethylbenzene (Weight %) 0.012 Xylene (mole %) 0.009 Xylene (Weight %) 0.038 n -Hexane (mole %) 0.324 n -Hexane (Weight %) 1.063 2, 2,4-Tri methyl pentane (mole %) 0.033 2, 2, 4-Trimethylpentane (Weight %) 0.141 Additional Required Information: • Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) I, F Farm APED -211 iSas Venting APEN Rev 03/2017 COLORADO 3I A ❑✓ Upward ❑ Horizontal Permit Number: 15WE0705 13 AIRS ID Number: `r. 123▪ /9A4C/ 007© mit arid fl-RS,>i Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.53672/-104.311004 Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. ("F) Flow Rate (ACFM) Velocity (ft/sec) EFLR-1 -15 -1000 Variable Indicate the direction of the stack outlet: (check one) ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap 48 Section 6 - Control Device Information ❑✓ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency VRU Downtime or Bypassed ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: 11.7 MMBtu/hr Type: Enclosed Combustor Make/Model: Cimarron 48" Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: 95 98 % Waste Gas Heat Content 1479 Btu/scf Constant Pilot Light: El Yes ❑ No Pilot burner Rating 0.05 MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0/0 COLORADO Form 1FCD-2 Natural Gas tin. ,PEi r 03/2017 f Permit Number: 15WE0705 13 AIRS ID Number: 1 230/ 9A4C/ 007© Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? D✓ Yes ❑ No describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO. VOC ECD 95 CO HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? Use the following table to report the criteria pollutant emissions from source: Pollutant Uncontrolled Emission Factor Emission Factor Units Emission Factor Source (AP -42, Mfg. etc) Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled (Tons/year) Controlled° (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM 40.0 pg/L^3 AP -42 N/A 0.21 SOX 0.00039 Ib/MMBtu AP -42 N/A 0.005 NO. 0.068 lb/MMBtu AP -42 N/A 0.83 VOC , is 28,142-38- lb/MMscf SSEF ;1.2., _>>_LI .2-27:71 A -1,39 -- CO 0.310 IbMMBtu AP -42 N/A 3. t -35 -9 — Benzene -09-11— Ib/MMscf SSEF 0.901 0.045 Toluene -0.-06a_ Ib/MMscf SSEF 0.491 0.025 Ethylbenzene 0-008_ Ib/MMscf SSEF 0.067 0.003 Xylenes 0_02-7 lb/MMscf SSEF 0.218 0.011 n -Hexane 0,759_ Ib/MMscf SSEF 6.084 0.304 2,2,4- Trimethylpentane 0400_ lb/MMscf SSEF 0.810 0.040 Other: N/A N/A 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Farm JAP_D-2':1 i•.irr.tal Gas 4ei-iti('g.,PEN Rev 03/2017 Permit Number: 15WE0705 13 AIRS ID Number: ll(F 123i 9A4C i 007© h4 Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. aa- . fl.le 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: ❑✓ Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 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 Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd FormAPCD-211 ,•+"rurat Gas r'e:tirw APtr; Rev Q3/2017 6 4 A COLORADO Hello