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Home My WebLink About20190252.tiffCOLORADO Department of Public Health & r nvironment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 January 3, 2019 Dear Sir or Madam: RECEIVED JAN 092019 WELD COUNTY COMMISSIONERS On January 10, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Bonanza North Platte 14-36. 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 & 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 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. PdeNi (he,t31 \1111 Lc GC.PLLTP),a.1.3T}, PWLIM1ELlr_tt1CAN 1101/1Ot 2019-0252 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Bonanza — North Platte 14-36 — Weld County Notice Period Begins: January 10, 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 Facility: North Platte 14-36 production facility SWSW, 5N, 63W, 36 Weld County The proposed project or activity is as follows: operator seeks to permit a 30 MMscf/day TEG dehydrator 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 13WE1092 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: Kirk Bear Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO COLORADO Air Pollution Control Division Department of Public Health 8- Environment CONSTRUCTION PERMIT Permit number: 13WE1092 Issuance: 6 Date issued: Issued to: Bonanza Creek Energy Operating Company, LLC Facility Name: North Platte 14-36 Production Facility Plant AIRS ID: 123 9AC9 Physical Location: SWSW, Section 36, T5N,-R63W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point Description CNDTK 01- 10 003 Ten 400 barrel condensate tanks L-01 007 Truck loadout of condensate P-01 011 One (1) Sandpiper G1F heat trace ciruclation pump (serial number: 1981452) rated at 600 scf/hr. DEHY-01 017 One (1) triethylene glycol (TEG) natural gas dehydration unit (make, model, serial number TBD) with a design capacity of 12.0 MMscfd. This emissions unit is equipped with two (2) Kimray 21015 gas -glycol pumps with a design capacity of 3.5 gpm. Only one Kimray gas -glycol pump will be operated at any given time. The second Kimray gas -glycol pump serves as backup only. This unit is equipped with a flash tank, reboiler, and still vent. Emissions from the still vent are routed to an air-cooled condenser and then to an enclosed flare. Emissions from the flash tank are 100% recycled to the sales gas line or to the fuel gas system. P-02 018 One (1) Sandpiper G1F heat trace ciruclation pump (serial number: 1981473) rated at 600 scf/hr. DEHY-02 020 One triethylene glycol natural gas dehydration unit (make, model, serial number to be determined) with a design capacity of 12.0 MMscf per day. This unit is equipped with 2 (1 for backup) Kimray PV21020 glycol pumps with a design capacity of 3.5 gallons per minute. This unit is equipped with a flash tank, reboiler and still vent. Stripping gas is injected into the still vent. 1COLORADO Pollutionrt Control Division ^at of w.tbk: !s3 n u Enaianavncne Page 1 of 24 DEHY-03 021 One triethylene glycol natural gas dehydration unit (make, model, serial number to be determined) with a design capacity of 30.0 MMscf per day. This unit is equipped with 2 (1 for backup) Kimray PV45020 glycol pumps with a design capacity of 7.5 gallons per minute. This unit is equipped with a flash tank, reboiler and still vent. Stripping gas is injected into the still vent. Gas Treater -02 022 One gas treater receiving gas from three separators Points 011, 018, 020, 021: This pump may be replaced with another pump in accordance with the provisions of the Alternate Operating Scenario (AOS) in this permit. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. 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/pacific/cdphe/other-air-permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. The following information must be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. 3. • manufacturer • model number • serial number This information must be included with the Notice of Startup submitted for the equipment. (Reference: Regulation Number 3, Part B, III.E.) 4. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self -certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) 5. This permit will 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.) 6. Point 021: Within one hundred and eighty days (180) after issuance of this permit, the operator shall install a flow meter to monitor and record volumetric flow rate of natural gas vented from each separator covered by this permit. Until the flow meter is installed, the operator shall monitor and record condensate/crude produced through the separator and estimate the gas flow rate based on standard cubic feet (scf) per barrel (bbl) of 85.5 scf/bbl estimated in the permit application. COLORADO +llnton Control Division Gor neht Page 2 of 24 7. 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.) 8. Point 017, 020, 021: The following information shall be provided to the Division within fifteen days of the latter of commencement of operation or issuance of this permit. • The dehydrator manufacturer name, model number and serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation Number 3, Part B, III.E.) 9. The operator must retain the permit final authorization letter issued by the Division after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 10. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: EQUIPMENT ID AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO CNDTK 01-10 003 -- 1.0 33.6 4.4 Point L-01 007 -- -- 0.4 -- Point P-01 011 -- -- 3.1 1.2 Point DEHY-01 017 -- -- 3.9 -- Point P-02 018 -- -- 3.1 1.2 Point DEHY-02 020 -- -- 6.8 2.1 Point DEHY-03 021 -- -- 14.0 2.3 Point Gas Treater -02 022 -- -- 7.0 1.1 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants will apply to all permitted emission units at this facility. Compliance with the annual limits for both criteria and hazardous air pollutants must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 11. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Reference: Regulation 3, Part C. II.E.) COLORADO Air Pollution Control Division €ieFara-mot of Pubto H &O tr Efwfrooment Page 3 of 24 Total emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, shall be less than 100 tons per year of VOC. 12. Point 017, 020, 021: Compliance with the emission limits in this permit shall be demonstrated by running the GRI GlyCalc model version 4.0 or higher on a monthly basis using the most recent extended wet gas analysis and recorded operational values, including: dry gas throughput, lean glycol recirculation rate, vapor recovery unit (VRU) downtime, chiller temperature and pressure, flash tank temperature and pressure, wet gas inlet temperature, and wet gas inlet pressure. Recorded operational values, except for gas throughput, shall be averaged on a monthly basis for input into the model and be provided to the Division upon request. 13. Point 017, 020, 021: On a weekly basis, the owner or operator shall monitor and record operational values including: vapor recovery unit downtime, chiller temperature and pressure, flash tank temperature and pressure, wet -gas inlet temperature and pressure. These records shall be maintained for a period of five years. 14. Point 017, 020, 021: The owner or operator shall operate and maintain the emission points in the table below as a closed loop system and shall recycle 100% of emissions as described in the table below. (Regulation Number 3, Part B, Section III.E.) 15. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment ID AIRS Point Control Device Pollutants Controlled CNDTK 01- 10 003 Enclosed combustor VOC and HAP L-01 007 Enclosed combustor VOC and HAP P-01 011 Enclosed flare VOC and HAP DEHY-01 017 Air-cooled condenser and enclosed flare for the still vent VOC and HAP P-02 018 Enclosed flare VOC and HAP DEHY-02 020 Still vent: Enclosed combustor VOC and HAP Flash tank: 100% recycle to fuel system or facility inlet DEHY-03 021 Still vent: Enclosed combustor VOC and HAP - Flash tank: 100% recycle to fuel system or facility inlet Gas Treater- 02 022 Enclosed combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 16. This source will be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate must be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, I.A.4) Process/Consumption Limits ;COLORADO Air Pollution Control Division `yg3P.r nt of Ffa,- fey rt E^wonn2n5 Page 4 of 24 Equipment ID AIRS Point Process Parameter Annual Limit CNDTK 01- 10 003 Condensate 54,312 barrels L-01 007 Condensate 54,312 barrels P-01 011 Venting of natural gas used to drive pneumatic pumps 5.26 MMscf DEHY-01 017 Natural gas throughput 4,380 MMscf P-02 018 Venting of natural gas used to drive pneumatic pumps 5.26 MMscf DEHY-2 020 - Dry gas 4,380 MMscf/year DEHY-3 021 Dry gas 10,950 MMscf/year Gas Treater -02 022 Separator gas -. 3.01 MMscf/year The owner or operator must calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 17. Point 007: Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation Number 3, Part B, III.E) 18. Point 017: This unit shall be limited to the maximum lean glycol circulation rate of 3.5 gallons per minute. The lean glycol recirculation rate shall be recorded as per the frequency required in the approved O&M Plan. This information shall be maintained in a log on site and made available to the Division for inspection upon request. (Reference: Regulation No. 3, Part B, II.A.4) 19. Point 020: This unit shall be limited to the maximum lean glycol circulation rate of 3.5 gallons per minute. The lean glycol recirculation rate shall be recorded daily in a log maintained on site and made available to the Division for inspection upon request. Glycol recirculation rate shall be monitored by one of the following methods: assuming maximum design pump rate, using glycol flow meter(s), or recording strokes per minute and converting to circulation rate. This maximum glycol circulation rate does not preclude compliance with the optimal glycol circulation rate (Loft) provisions under MACT HH. (Reference: Regulation Number 3, Part B, II.A.4) 20. Point 021: This unit shall be limited to the maximum lean glycol circulation rate of 7.5 gallons per minute. The lean glycol recirculation rate shall be recorded daily in a log maintained on site and made available to the Division for inspection upon request. Glycol recirculation rate shall be monitored by one of the following methods: assuming maximum design pump rate, using glycol flow meter(s), or recording strokes per minute and converting to circulation rate. This maximum glycol circulation rate does not preclude compliance with the optimal glycol circulation rate (Loot) provisions under MACT HH. (Reference: Regulation Number 3, Part B, II.A.4) 21. Upon installation of the flow meter, 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 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 COLORADO ar Fottunon Control Division of Page 5 of 24 22. Point 003, 020, 021, 022: The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 23. 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.) 24. Point 007: 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 and emissions shall be controlled by a flare. (Reference: Regulation 3, Part B, III.D.2) 25. Point 007: 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. 26. Point 007: 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.D.2): a. The owner or operator shall inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. b. All compartment hatches at the facility (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. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. e. Document annual inspections of thief hatch seals and PRD with an n indication of status, a description of any problems found, and their resolution. 27. Point 007: For this controlled loading operation, 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.D.2): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. 28. Visible emissions must not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment. visible emissions must not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation Number 7, Sections XII.C.1.d or COLORADO x Pollution Control Division r,rent of iajo'ae Page 6 of 24 XVII.B.2.b must have no visible emissions. (Reference: Regulation Number 1, Section II.A.1. & 4.) 29. Point 003, 007, 020, 021, 022: This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 30. Point 003: 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, br by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XILC.) (State only enforceable) 31. Point 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. 32. Point 003: The storage tank covered by this permit is 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 fora 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. 33. Point 003: 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. 34. Points 011 and 018: This source is subject to the requirements of Regulation Number 7, Sections XII.C and XII.K.2 including but not limited to: • Beginning May 1, 2018, the owner or operator of each natural gas -driven diaphragm pneumatic pump located at a well production facility must reduce volatile organic compound emissions from the pneumatic pump by 95% if it is technically feasible to route emissions to an existing control device or process at the well production facility. • All air pollution control equipment used to demonstrate compliance with Section XII.K must meet a control eficiency of at least 95%. • The combustion device controlling emissions from the pneumatic pump(s) must be enclosed, have no visible emissions, and be designed so that an observer can, by means ;COLORADO Pollution Control Division . rsi ai PUbrc E^worr-tent Page 7 of 24 of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. • All combustion devices installed on or after January 1, 2018 and used to comply with Section XII.K must be equipped with an operational auto -ignitor upon installation of the combustion device. 35. Points 011 and 018: This source is subject to the recordkeeping requirements of Regulation Number 7, Section XII.K.3. 36. Point 017: The flare(s) covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). These requirements include, but are not limited to: XVII.B.2.b If a 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, 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. XVII.B.2.d Auto -igniters: All combustion devices used to control emissions of hydrocarbons must be equipped with and operate an auto -igniter as follows: XVII.B.2.d.(i) All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device. XVII.B.2.d.(ii) 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. 37. Point 020, 021, 022: 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.17; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 38. Point 017: This equipment is subject to the control requirements for glycol natural gas dehydrators under Regulation No. 7, Section XII.H. Beginning May 1, 2005, uncontrolled actual emissions of volatile organic compounds from the still vent and vent from any gas -condensate - glycol (GCG) separator (flash separator or flash tank), if present, shall be reduced by at least 90 percent through the use of air pollution control equipment. This source shall comply with all applicable general provisions of Regulation 7, Section XII. 39. Point 017: This equipment is subject to the control requirements for glycol natural gas dehydrators under Regulation No. 7, Section XVII.D. (State only enforceable). These requirements include, but are not limited to: XVII.D.3. Beginning May 1, 2015, still vents and vents from any flash separator or flash tank on a glycol natural gas dehydrator located at an oil and gas exploration and production operation, natural gas compressor station, or gas -processing plant subject to control - requirements pursuant to Section XVII.D.4., shall reduce uncontrolled actual emissions of hydrocarbons by at least 95 percent on a rolling twelve-month basis through the use of a, COLORADO Aix Pollution Control Diirisior% Pubtc Weartn Fz ^.v�ranrr.�r; Page 8 of 24 condenser or air pollution control equipment. If a combustion device is used, it shall have a design destruction efficiency of at least 98% for hydrocarbons. XVII.D.4. The control requirement in Section XVII.D.3. shall apply where: XVII.D,4.a. Uncontrolled actual emissions of VOCs from a glycol natural gas dehydrator constructed on or after May 1, 2015, are equal to or greater than two (2) tons per year. Such glycol natural gas dehydrators must be in compliance with Section XVII.D.3. by the date that the glycol natural gas dehydrator commences operation. 40. Point 020, 021, 022: The glycol dehydration unit covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.D.3. Beginning May 1, 2015, still vents and vents from any flash separator or flash tank on a glycol natural gas dehydrator located at an oil and gas exploration and production operation, natural gas compressor station, or gas - processing plant subject to control requirements pursuant to Section XVII.D.4., shall reduce uncontrolled actual emissions of hydrocarbons by at least 95% on a rolling twelve-month basis through the use of a condenser or air pollution control equipment. 41. Point 017: This source is subject to the requirements of 40 CFR, Part 63, Subpart HH - National Emission Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production Facilities including, but not limited to, the following: • §63.764 - General Standards o §63.764 (e)(1) -The owner or operator is exempt from the requirements of paragraph (d) of this section if the criteria listed in paragraph (e)(1)(i) or (ii) of this section are met, except that the records of the determination of these criteria must be maintained as required in §63.774(d)(1). ■ §63.764 (e)(1)(ii) — The actual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere are less than 0.90 megagram per year, as determined by the procedures specified in §63.772(b)(2) of this subpart. • §63.772 - Test Methods, Compliance Procedures and Compliance Demonstration o §63.772(b) - Determination of glycol dehydration unit flowrate or benzene emissions. The procedures of this paragraph shall be used by an owner or operator to determine glycol dehydration unit natural gas flowrate or benzene emissions to meet the criteria for an exemption from control requirements under §63.764(e)(1). ■ §63.772(b)(2) - The determination of actual average benzene emissions from a glycol dehydration unit shall be made using the procedures of either paragraph (b)(2)(i) or (b)(2)(ii) of this section. Emissions shall be determined either uncontrolled, or with federally enforceable controls in place. • §63.772(b)(2)(i) — The owner or operator shall determine actual. average benzene emissions using the model GRI-GLYCaIc TM Version 3.0 or higher, and the procedures presented it the associated GRI-GLYCaIc TM Technical Reference Manual. Inputs to the model shall be representative of actual operating conditions of the glycol dehydration unit and may be determined using the procedures documented in the Gas Research Institute (GRI) report entitled "Atmospheric Rich/Lean Method for Determining Glycol Dehydrator Emissions" (GRI-95/0368.1); or • §63.772(b)(2)(ii) - The owner or operator shall determine an average mass rate of benzene emissions in kilograms per hour through direct measurement using the methods in §63.772(a)(1)(i) or (ii), or an alternative method according to §63.7(f). Annual emissions in kilograms per year shall be determined by multiplying the mass rate COLORADO Air Pollution Control Dyson ,ANttz. Yean fr z.^.'wonm,,fl Page 9 of 24 by the number of hours the unit is operated per year. This result shall be converted to megagrams per year. • §63.774 - Recordkeeping. Requirements o §63.774 (d)(1) - An owner or operator of a glycol dehydration unit that meets the exemption criteria in §63.764(e)(1)(i) or §63.764(e)(1)(ii) shall maintain the records specified in paragraph (d)(1)(i) or paragraph (d)(1)(ii) of this section, as appropriate, for that glycol dehydration unit. ■ §63.774 (d)(1)(ii) - The actual average benzene emissions (in terms of benzene emissions per year) as determined in accordance with §63.772(b)(2). 42. Point 020, 021: This source is subject to Regulation Number 7, Section XII.H. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for glycol natural gas dehydrators; and • Ensure uncontrolled actual emissions of volatile organic compounds from the still vent and vent from any gas -condensate -glycol (GCG) separator (flash separator or flash tank), if present, shall be reduced by at least 90 percent on a rolling twelve-month basis through the use of a condenser or air pollution control equipment. (Regulation Number 7, Section XII.H.1.) 43. Point 020, 021: The glycol dehydration unit at this facility is subject to National Emissions Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production Facilities, Subpart HH. This facility shall be subject to applicable area source provisions of this regulation, as stated in 40 C.F.R Part 63, Subpart A and HH. (Regulation Number 8, Part E, Subpart A and HH) COLORADO Air Pollution Control Division! Page 10 of 24 MACT HH Applicable Requirements Area Source Benzene emissions exemption §63.764 - General Standards §63.764 (e)(1) - The owner or operator is exempt from the requirements of paragraph (d) of this section if the criteria listed in paragraph (e)(1)(i) or (ii) of this section are met, except that the records of the determination of these criteria must be maintained as required in §63.774(d)(1). §63.764 (e)(1)(ii) - The actual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere are less than 0.90 megagram per year, as determined by the procedures specified in §63.772(b)(2) of this subpart. §63.772 - Test Methods, Compliance Procedures and Compliance Demonstration §63.772(b) - Determination of glycol dehydration unit flowrate or benzene emissions. The procedures of this paragraph shall be used by an owner or operator to determine glycol dehydration unit natural gas flowrate or benzene emissions to meet the criteria for an exemption from control requirements under §63.764(e)(1). §63.772(b)(2) - The determination of actual average benzene emissions from a glycol dehydration unit shall be made using the procedures of either paragraph (b)(2)(i) or (b)(2)(ii) of this section. Emissions shall be determined either uncontrolled, or with federally enforceable controls in place. §63.772(b)(2)(i) - The owner or operator shall determine actual average benzene emissions using the model GRI-GLYCaIc TM, Version 3.0 or higher, and the procedures presented in the associated GRI-GLYCaIc TMTechnical Reference Manual. Inputs to the model shall be representative of actual operating conditions of the glycol dehydration unit and may be determined using the procedures documented in the Gas Research Institute (GRI) report entitled "Atmospheric Rich/Lean Method for Determining Glycol Dehydrator Emissions" (GRI-95/0368.1); or §63.772(b)(2)(ii) - The owner or operator shall determine an average mass rate of benzene emissions in kilograms per hour through direct measurement using the methods in §63.772(a)(1)(i) or (ii), or an alternative method according to §63.7(f). Annual emissions in kilograms per year shall be determined by multiplying the mass rate by the number of hours the unit is operated per year. This result shall be converted to megagrams per year. !COLORADO Air Pollution Control Division 7.Xparea^.en[ of Puti` Hken a cr,ironment Page 11 of 24 §63.774 Recordkeeping Requirements §63.774 (d)(1) - An owner or operator of a glycol dehydration unit that meets the exemption criteria in §63.764(e)(1)(i) or §63.764(e)(1)(ii) shall maintain the records specified in paragraph. (d)(1)(i) or paragraph (d)(1)(ii) of this section, as appropriate, for that glycol dehydration unit. §63.774 (d)(1)(ii) The actual average benzene emissions (in terms of benzene emissions per year) as determined in accordance with §63.772(b)(2). COLORADO Control Division tronmert Page 12 of 24 MACT HH Applicable Requirements Area Source Outside UA/UC boundary §63.760 - Applicability and designation of affected source §63.760 (f) - The owner or operator of an affected major source shall achieve compliance with the provisions of this subpart by the dates specified in paragraphs (f)(1) and (f)(2) of this section. The owner or operator of an affected area source shall achieve compliance with the provisions of this subpart by the dates specified in paragraphs (f)(3) through (f)(6) of this section. §63.764 - General Standards §63.764 (d)(2) -Each owner or operator of an area source not located in a UA plus offset and UC boundary (as defined in §63.761) shall comply with the provisions specified in paragraphs (d)(2(i) through (iii) of this section. §63.764 (d)(2)(i) - Determine the optimum glycol circulation rate using the following equation: Lori=1.15*3.0gal TEG* F*(/ —O)\ 1b1-12O(24hr/day 1 Where: LOPT = Optimal circulation rate, gal/hr. F = Gas flowrate (MMSCF/D) I = Inlet water content (lb/MMSCF) O = Outlet water content (lb/MMSCF) 3.0 = The industry accepted rule of thumb for a TEG-to water ratio (gal TEG/lbH2O) 1.15 = Adjustment factor included for a margin of safety. §63.764 (d)(2)(ii) - Operate the TEG dehydration unit such that the actual glycol circulation rate does not exceed the optimum glycol circulation rate determined in accordance with paragraph (d)(2)(i) of this section. If the TEG dehydration unit is unable to meet the sales gas specification for moisture content using the glycol circulation rate determined in accordance with paragraph (d)(2)(i), the owner or operator must calculate an alternate circulation rate using GRI-GLYCalcTM, Version 3.0 or higher. The owner or operator must document why the TEG dehydration unit must be operated using the alternate circulation rate and submit this documentation with the initial notification in accordance with §63.775(c)(7). §63.764 (d)(2)(iii) - Maintain a record of the determination specified in paragraph (d)(2)(ii) in accordance with the requirements in 563.774(f) and submit the Initial Notification in accordance with the requirements in §63.775(c)(7). If operating conditions change and a modification to the optimum glycol circulation rate is required, the owner or operator shall prepare a new determination in accordance with paragraph (d)(2)(i) or (ii) of this section and submit the information specified under §63.775(c)(7)(ii) through (v). ICOLOR ADO Air Pollution Control Divis ?O pm•J ven, Page 13 of 24 MACT HH Applicable Requirements Area Source Outside UA/UC boundary §63.774 (b) - Except as specified in paragraphs (c), (d), and (f) of this section, each owner or operator of a facility subject to this subpart shall maintain the records specified in paragraphs (b)(1) through (11) of this section §63.774 (b)(1) §63.774 (b)(1) - The owner or operator of an affected source subject to the provisions of this subpart shall maintain files of all information (including all reports and notifications) required by this subpart. The files shall be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report or period. §63.774 (b)(1)(i) - All applicable records shall be maintained in such a manner that they can be readily accessed. §63.774 - §63.774 (b)(1)(ii) - The most recent 12 months of records shall be Recordkeeping retained on site or shall be accessible from a central location by Requirements computer or other means that provides access within 2 hours after a request. §63.774 (b)(1)(iii) - The remaining 4 years of records may be retained offsite. §63.774 (b)(1)(iv) - Records may be maintained in hard copy or computer -readable form including, but not limited to, on paper, microfilm, computer, floppy disk, magnetic tape, or microfiche. §63.774 (f) - The owner or operator of an area source not located within a UA plus offset and UC boundary must keep a record of the calculation used to determine the optimum glycol circulation rate in accordance with §63.764(d)(2)(i) or §63.764(d)(2)(ii), as applicable. COLORADO r pollution Control Division. q(-Publ.₹aaaP Fr E;;rvonr-mr. Page 14 of 24 §63.775 (c) - Except as provided in paragraph (c)(8), each owner or operator of an area source subject to this subpart shall submit the information listed in paragraph (c)(1) of this section. If the source is located within a UA plus offset and UC boundary, the owner or operator shall also submit the information listed in paragraphs (c)(2) through (6) of this section. If the source is not located within any UA plus offset and UC boundaries, the owner or operator shall also submit the information listed within paragraph (c)(7). §63.775 (c)(1) - The initial notifications required under §63.9(b)(2) not later than January 3, 2008. In addition to submitting your initial notification to the addressees specified under §63.9(a), you must also submit a copy of the initial notification to EPA's Office of Air Quality Planning and Standards. Send your notification via e-mail to CCG-ONG®EPA.GOV or via U.S. mail or other mail delivery service to U.S. EPA, Sector Policies and Programs Division/Coatings and Chemicals Group (E143-01), Attn: Oil and Gas Project Leader, Research Triangle Park, NC 27711. §63.775 (c)(7) - The information listed in paragraphs (c)(1)(i) through (v) of this section. This information shall be submitted with the initial notification. §63.775 - Reporting Requirements §63.775 (c)(7)(i) - Documentation of the source's location relative to the nearest UA plus offset and UC boundaries. This information shall include the latitude and longitude of the affected source; whether the source is located in an urban cluster with 10,000 people or more; the distance in miles to the nearest urbanized area boundary if the source is not located in an urban cluster with 10,000 people or more; and the names of the nearest urban cluster with 10,000 people or more and nearest urbanized area. §63.775 (c)(7)(ii) - Calculation of the optimum glycol circulation rate determined in accordance with §63.764(d)(2)(i). §63.775 (c)(7)(iii) - If applicable, documentation of the alternate glycol circulation rate calculated using GRI-GLYCalcTM, Version 3.0 or higher and documentation stating why the TEG dehydration unit must operate using the alternate glycol circulation rate. §63.775 (c)(7)(iv) - The name of the manufacturer and the model number of the glycol circulation pump(s) in operation. §63.775 (c)(7)(v) - Statement by a responsible official, with that official's name, title, and signature, certifying that the facility will always operate the glycol dehydration unit using the optimum circulation rate determined in accordance with §63.764(d)(2)(i) or §63.764(d)(2)(ii), as applicable. COLORADO n Control Division tob0c$44a hti Environment t Page 15 of 24 MACT HH Applicable Requirements Area Source Outside UA/UC boundary §63.775 (f) - Notification of process change. Whenever a process change is made, or a change in any of the information submitted in the Notification of Compliance Status Report, the owner or operator shall submit a report within 180 days after the process change is made or as a part of the next Periodic Report as required under paragraph (e) of this section, whichever is sooner. The report shall include: §63.775 (f)(1) - A brief description of the process change; §63.775 (f)(2) - A description of any modification to standard procedures or quality assurance procedures §63.775 (f)(3) - Revisions to any of the information reported in the original Notification of Compliance Status Report under paragraph (d) of this section; and §63.775 (f)(4) - Information required by the Notification of Compliance Status Report under paragraph (d) of this section for changes involving the addition of processes or equipment. OPERATING & MAINTENANCE REQUIREMENTS 44. Point 003, 007, 020, 021, 022: Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) 45. Point 017: The condenser outlet temperature shall be recorded as per the frequency required in the approved O&M Plan. This information shall be maintained in a log on site and made available to the Division for inspection upon request. The condenser outlet temperature shall not exceed 150°F on a monthly average basis. COMPLIANCE TESTING AND SAMPLING INITIAL TESTING REQUIREMENTS 46. Point 003: The owner or operator shall complete site specific sampling including a compositional analysis of the pre -flash pressurized condensate routed to these storage tanks and, if necessary for emission factor development, a sales oil analysis to determine RVP and API gravity. Testing shall be in accordance with the guidance contained in PS Memo 05-01. Results of testing shall be used to determine site -specific emissions factors for V0C and Hazardous Air Pollutants using Division approved methods. Results of site -specific sampling and analysis shall be submitted to the Division as part of the self -certification and used to demonstrate compliance with the emissions factors chosen for this emissions point. 47. Point 003, 020, 021, 022: The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) COLORADO Air ottution Contzoi Division r'anelt PAitik }tee ^iv'cnvir°nment Page 16 of 24 48. Point 020, 021: The owner or operator shall complete the initial extended wet gas analysis within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit. The owner or operator shall use this analysis to calculate actual emissions, as prescribed in the Emission Limitation and Records section of this permit, to verify initial compliance with the emission limits. The owner or operator shall submit the analysis and the emission calculation results to the Division as part of the self -certification process. (Reference: Regulation Number 3, Part B, Section III.E.) 49. Point 022: The owner/operator'shall complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the natural gas vented from this emissions unit in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n -hexane, and 2,2,4- trimethylpentane content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be submitted to the Division as part of the self -certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). PERIODIC TESTING REQUIREMENTS 50. Point 003, 020, 021: The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, on a weekly basis to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) 51. Point 017, 020, 021: The owner or operator shall complete an extended wet gas analysis prior to the inlet of the TEG dehydrator on an annual basis. Results of the wet gas analysis shall be used to calculate emissions of criteria pollutants and hazardous air pollutants per this permit and be provided to the Division upon request. 52. Point 022: On an annual basis, the owner/operator shall complete a site specific extended gas analysis ("Analysis") of the natural gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be used to demonstrate that the emissions factor established through the Analysis are less than or equal to, the emission factor submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factor submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). ALTERNATE OPERATING SCENARIOS: POINTS 011 AND 018 53. This pump may be replaced with a like -kind pump in accordance with the requirements of Regulation 3, Part A, Section IV.A and without applying for a revision to this permit or obtaining a new construction permit. A like -kind replacement pump must be the same make, model and capacity as authorized in this permit. COLORADO Air Pollution Control Division a7 Publ c € taut v Environment Page 17 of 24 54. The owner or operator must maintain a log on -site or at a local field office to contemporaneously record the start and stop dates of any pump replacement, the manufacturer, model number, serial number and capacity of the replacement pump. 55. All pump replacements installed and operated per the alternate operating scenarios authorized by this permit must comply with all terms and conditions of this construction permit. ADDITIONAL REQUIREMENTS 56. All previous versions of this permit are cancelled upon issuance of this permit. 57. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 58. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this stationary source at any such time that this stationary source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part E) 59. MACT Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of that Subpart on the date as stated in the rule as published in the Federal Register. (Reference: Regulation No. 8, Part E) GENERAL TERMS AND CONDITIONS 60. 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. COLORADO Air Pollution Control Division rtment of kf b, , Page 18 of 24 61. 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. 62. 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. 63. 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. 64. 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 will constitute a rejection of the entire permit and upon such occurrence, this permit will 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. 65. 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. 66. 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: Kirk Bear MA Permit Engineer Permit History Issuance Date ' Description Issuance 1 July 5, 2013 Issued to Bonanza Creek Energy Operating Company LLC Issuance 2 January 6, 2015 Modification to point 003; addition of one 400 bbl tank; total battery capacity is 4,000 bbl. Issuance 3 July 23, 2015 Added new point, AIRS ID 017, for a TEG dehy Removed Points 005, 006 and 009 which had been COLORADO i Air Pollution Control Division rtrrte t. RtacNea na E.^..vorvxt rt Page 19 of 24 previously cancelled by the source. Issuance 4 July 28, 2017 Issued to Bonanza Creek Energy Operating Company, LLC. Modified point 011 to change the requested hours of operation per pump, to update the vent rate to 600 scf/hr, and to update the sales gas analysis. Removed point 003 (now GP01), point 004 (now GP05), and point 010 (cancelled). Updated permit requirements, for point 007 to meet current standard. Issued as Initial Approval. Issuance 5 22 March 2018 Moved P-02 (previously under Point 011) to a new point (Point 018). Added permit conditions for Points 011 and 018 to reflect current standards. Removed Point 007. Cancellation request received 10/6/2017. Issuance 6 This issuance Add Points 003, 007, 020, 021, and Point 022 COLORADO Air Pollution Control Division zc 91ERK', a cnttirenrty^s,: Page 20 of 24 Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point CAS # Pollutant Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 003 71432 Benzene 4006 202 108883 Toluene 1726 88 100414 Ethylbenzene 94 6 1330207 Xylenes 316 16 110543 n -Hexane 50534 2528 540841 224 TMP 498 26 007 71432 Benzene 22 1 110543 n -Hexane 196 10 011 & 018, each 71432 Benzene 399 20 108883 Toluene 372 19 100414 Ethylbenzene 27 2 1330207 Xylenes 109 6 110543 n -Hexane 2192 110 540841 224 TMP 6 1 017 71432 Benzene 71237 1678 108883 Toluene 105536 1361 100414 Ethylbenzene 11384 67 1330207 Xylenes 80857 428 COLORADO Air Pollution Control Division rirneot o fhat o Heats & c!".'(irhnl".£s?t Page 21 of 24 110543 n -Hexane 18421 196 020; 71432 Benzene 26258 1242 108883 Toluene 33080 1596 100414 Ethylbenzene 2886 142 1330207 Xylenes 16146 796 110543 n -Hexane 9266 226 540841 224 TMP 31 1 021 71432 Benzene 52956 2503 108883 Toluene 66827 3221 100414 Ethylbenzene 5839 286 1330207 Xylenes 33102 1631 110543 n -Hexane 18739 458 540841 224 TMP 62 2 02.2 71432 Benzene 544 28 108883 Toluene 142 8 100414 Ethylbenzene 6 2 1330207 Xylenes 10 2 110543 n -Hexane 11368 570 540841 224 TMP 14 2 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (Ib/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 003: CAS # Pollutant Uncontrolled Emission Factors Source NOx 0.068 lb/MMBtu CDPHE CO 0.310 lb/MMBtu CDPHE VOC 24.75 lb/bbl Operator 71432 Benzene 0.09 Ib/bbl Operator 108883 Toluene 0.04 Ib/bbl Operator 100414 Ethylbenzene 0.001 lb/bbl Operator 1330207 Xylene 0.01 lb/bbl Operator 110543 n -Hexane 1.12 lb/bbl Operator 540841 224 TMP 0.01 lb/bbl Operator Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. Point 007: Pollutant CAS # Uncontrolled Emission Factors Source NOx 0.068 Ib/MMBtu AP -42 CO 0.310 lb/MMBtu AP -42 ICOLORA©O Air Pollution Control Division rrant aI Il:bGo }4e3i,@^,vironrrtent Page 22 of 24 Pollutant CAS # Uncontrolled Emission Factors Source VOC 0.23600 lb/bbl Operator Benzene 71432 0.00041 lb/bbl Operator n -Hexane 110543 0.00360 lb/bbl Operator Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. Points 011 and 018: CAS # , Pollutant - Uncontrolled Emission Factors lb/MMscf Controlled Emission Factors lb/MMscf Source CO 448.669 AP -42 VOC 23,338.48 1166.92 All emission factors are based on the displacement equation and a wet gas analysis collected November 2014. 71432 Benzene 75.7878 3.79 108883 Toluene 70.6822 3.53 100414 Ethylbenzene 5.0392 0.25 1330207 Xylene 20.7537 .- 1.04 110543 n -Hexane 416.9325 20.85 540841 224 TMP 1.0608 0.05 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. Point 017, 020, 021: The emission levels contained in this permit are based on information provided in the application and the GRI GlyCalc 4.0 model. Point 022: CAS # Pollutant Uncontrolled Emission Factors Source NOx 0.068 lb/MMBtu AP -42 CO 0.310 lb/MMBtu AP -42 VOC 920991b/MMscf Operator 71432 Benzene 180.29 lb/MMscf Operator 108883 Toluene 46.84 lb/MMscf Operator 100414 Ethylbenzene 1.50 lb/MMscf Operator 1330207 Xylene 3.12 lb/MMscf Operator 110543 n -Hexane 3776.43 lb/MMscf Operator 540841 224 TMP 4.39 lb/MMscf Operator Note: The controlled emissions factors for this point 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 must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the glycol dehydration unit and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(B) when applicable. ,COLORADO I Air Pollution Control Division • C.pa t ent of €.. Heaith }a 5nitronment Page 23 of 24 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic minor source of: VOC, NOx, Total HAP, Benzene, Toluene, Xylenes, n -Hexane NANSR Synthetic Minor Source of: VOC MACT HH Area Source MACT ZZZZ Area Source 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 Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXX)CCX COLORADO Air Pollution Control Division Mee onr-tent Page 24 of 24 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package 6: Received Date: 2'1f$/2418 Review Start Date: 92/13/201 Section 01- Facility Information Company Name: Bonanza Creek E r,gyuQperating Company, LLC County AIRS ID: Plant AIRS ID:, Facility Name: Physical Address/Location: County: Type of Facility: What industry segment? 4zit;i≥E-;Itistyta€',,t ee Predh Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) SACS North:PletteT4-3„6: SWSW quadrant of Section 56, Township 63W, Range 36W Weld County Section 02 - Emissions Units In Permit Application Quadrant Section Township I Range SWSW.-_:::: Particulate Matter (PM) J ozone (uox & VOC) N AIRs Point tt Emissions Source Type Emissions Equipment Name Permit tt Issuance S Control? Self Cert Required? Action Engineering Remarks CNDTK 01-10 Yes 13 W E1092 Yes 021 022 pastor Venting ." Gas Treater -02 Yes 09 DE60-03 " Yes 13WE1C9? Yes Permit; Mo€s i ttcatfan; Permit . tdificataan ertnit ifidati9n Section 03 - Description of Project Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? 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 (P5D) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR)- S02 NOx CO VOC PM2.5- PM10 TSP HAPs ❑ El Colorado Air Permitting. Project Is this stationary source a major source? If yes, explain what programs and which pollutants hurt SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) NOx CO VOC PM2.5 PM10 TSP HAPs ❑ Q Glycol Dehydrator Ernissions'l'nvedtory 020 Dehydrator (Facility AIRS ID: Coon Plante Poin Section 02 - Equipment Description Details Dehydrator Information DehydratorType: Make: - •Model: • Serial Number: Design Capacity: Recirculation Pump Information 'Number of Pumps Pump Type Make: Model: Design/Max Recirculation Rate: Dehydrator Equipment Flash Tank Reboiler Burner Stripping Gas Dehydrator Equipment Description gallons/minute , flash tank, - and reboiler burner Stripping gas is injected into the reboller. One (1) Triethylene glycol (TEG). natural gas dehydration unit (Make: TOO, Model: TOD, Serial Number: TBO) with a design capacity of 12 MMscf per day. This emissions unit is equipped with 2 (Makes Kimray,Model: P021020) gas driven glycol pump with a design capacity of 3.5 gallons per minute. This dehydration unit is equipped .with a still vent, flash tank, and reboller burner. Stripping gas Is injected into the reboiler. - Emission Control -Device Description: - Emissions from the still vent are routed to the Erelosed Flare. Emissions from the flash tank are routed directly to the olosed-loop system. Section 03 Processing Rate Information for Emissions Estimates - Primary Emissions - Dehydrator Still Vent and Flash Tank (if present) Requested Permittimlt Throughp t O1Vi t. _j( MMscfperyear Requested Monthly Throughput= 372 MMscfpermonth Potential to Emit (POE) Throughput= 4,380 MMscf per year r Secondary Emissions-- Combustion Device(s) for Air Pollution Control Still Vent Control Condenser: Condenser emissionreduction claimed: Primary control device: Primary. control device operation: Seoondery,contnol device:., Secondary control device operation: Still Vent Gas Heating Value: Still Vent Waste Gas Vent Rate: • - Flash tank Control Primary control device: Primary control device operation: Secondary control device: Secondary control device operation: Flash Tank Gas Heating Value Flash Tank Waste Gas Vent Rate: Section 04- Emissions Factors & Methodologies Dehydrator Requested Cd Outlet Temperature: 9531 Control Efficiency % Requested TOTemp ,f Control Efficiency % hr/Y, Btu/scf scfh 'Input Parameters Inlet Gas Pressure Inlet Gas Temperature Requested Glycol Recirculate Rate STILL VENT Control Scenario Primary Secondary Pollutant Uncontrolled (lb/hr) Controlled (lb/hr) Controlled (lb/hr) VOC 30971,6 ?.,,i 1.5489 309776 Benzene v(;? Z88S6.. I.,;'; :1. 0.1418 2.8356 Toluene 3.0407 '. 0.1621 3.£427 Ethylbenzene 1,, 0 32x8 - 0.0161 0.3226 Xylenes: ---5,0300 ,,�' 0.0908 Lutes n -Hexane 03141 ;': ii s 0,0257 6,5141 224-TMP ,. 0,005.0 % - 0.0001 0.0018 FLASH TANK - Control Scenario Primary Secondary Pollutant Uncontrolled(Ib/hr) Controlled (lb/hr) Controlled (lb/hr) HOC ,:': ;,,,::22.SQ§2.. .,.:. 0 326052 Benzene AlENOV16Ls ::.,%;,:'. 0 0.1619 Toluene fl3,338 j,,,;; iti. 0 0.1336 Ethylbenzene' ll11.13i'0406BnlleNglll, 0 0.0069 Xylenes er6 D,tj266 i 0 0.0266 n -Hexane 05437. ?..I?„:• 0. 0.5437 224-TMP ,,,,,,, ;-fl.0017 . 0 .0.0017 Degrees F 24,840 Dry Gas Throughput: Still Vent Primary Control: . 4,380.0 MMscf/yr Still Vent 5econdary Control: 0.0 MMscf/yr Waste Gas Cem busted: Still Vent Primary Control: 15.6 MMscfjyr Still Vent Secondary Control: 0.0. MMscf/yr Dry Gas Throughput Flash Tank Primary Control: 4,380.0 MMscf/yr Flash Tank Secondary Control: 0.0 MMscf/yr Waste Gas Combusted: Flash Tank Primary Control: 0.0 MMscf/yr Flash -Tank Secondary Control: OA MMscf/yr 13WE1092 dehy2 Component HhN (Btu/sof) mole % CO2 0.0 N2 0.0 methane 1012 ethane propane Isebutane n -butane Isepentane n -pentane Hexanes heptanes Octanes Nananes 1783.00 2557.00 3354.00 3369.00 4001.00 4009.00 4745.00 5502.50 6248.90 6996.5 1.39 0.186 25.5 5.82 3.79 0.464 1.52 0.234 0.326 0.4 0.222 0.413 Decanes+ 7742.9 Benzene 3741.80 0:772 Toluene 4475.00 0.84 Ethylbenzene 5222.20 0.0646 Xylenes 5208.00 0.364 n -Hexane 4755.90 0.127 22 -4 -IMP (HHS. 6248.90 0.000329 42.232929 Heating Value 69616 Btulsof 372.0 Glycol Dehydrator Emissions Inventory Emission Factors Glycol Dehydrator Pollutant Uncontrolled Controlled (Ib/MMsef). (lb/MMsef) (DryGas Throughput) (Dry Gas Throughput). VOC 127.17 5.995 3.10 Benzene Toluene 7.5526 0.28356 0.36427 _ 0.03226 0.18166 0.05141 0.00018 Ethylbenzene 0.659 3.6864 2.1156 0.007 Xylene n -Hexane 224 IMP Pollutant PM10 PM2.5 SOx NOx CO „b,$lDD•-;:. - Still Vent Primary Control Device Uncontrolled (lb/MM Btu) Uncontrolled (lb/MMscf) (Waste Gas combusted) (Waste Heat ' Combusted)• 0.000,0 0.0000 0.0000 47.3450 215.8375 Pollutant Still Vent Secondary Control Device Uncontrolled Uncontrolled_ (Ib/MMBtu) (Ib/MMscf) (Waste Heat (WasteGas Combusted) Combusted). PM10 PM2.5 SOx NOx CO 0.0000 0.0000 0.0000 0.0000 0:0000 Pollutant Flash Tank Primary Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (Ib/MMsct) (Waste Heat (Waste Gas Combusted). Combusted) PM10 0.0000 ' 0.0000 0.0000 93.6360 426.8700 000 CO ., "b,3$OR;diii. Pollutant Flash Tank Secondary Control Device Uncontrolled Uncontrolled _ (Ib/MMBtu) (lb/MMscf( (Waste Heat (Waste Gas - Combusted) Combusted)' PM10 PM2.5 SON NON CO 0-0000 0.0000 0.0000 0.0000 0,0000 Section 05 Emissions Inventory Did operator request a buffer? Requested Buffer (%): Emission Factor Source Emission Factor Source. Emission Factor Source Emission Factor Source Emission Factor Source http://www.enggcyclopedia.corn/2011/09/heating-values-natural-gas/ 13W61092 dehy 2 flash tank off gas Calculation of High Heating Value with Know Gal. assume . volume % equals mole % Component HHV (Btu/scfl mole % CO2 0 3.73 N2 ' 0 0.491 Methane 1012 65.9 ethane 1783 15 propane 2557 9.02 isobutane 3354 0.989 n -butane 3369 3.01 isopentane 4001 0:422 n -pentane 4009 - 0.541 Heaanes. 4745 0.3501 heptanes 5502.5 0.157 Octanes 6248.9 0.0334 Nonanes 6996.5 Decones+ 7742.9 Benzene. 3741.8 0.0494 Toluene 4475 0.0346 Ethylbenzene 5222.2 0.00154 XYlenes 5208 0.00596 n -Hexane 4755.9 0.15 224 -IMP (OHS 6248.9 0.000359 99.893359 Heating Value of Gas I. 1377 Btu/scf http://www.engoNdloped ia.com/2011/09/he sting -values -natural-gas/. 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)' PM10 0.0 0.0 0.0 ' 0.0. 0.0' PM2.5 0.0 0.0 0.0 0.0 0.0 SOx 0.0 0-0 0.0 0.0 0.0 NOx 0.4 0.4 0.4 0.4 0.4 _ CO 1.7 17 1-7 1.7 1.7 VOC 278.5 278.5 6.8 278:5 6.8 Potential to Emit ActualEmissions Requested Pe mit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled .Controlled Uncontrolled Controlled (Ibs/year) (Ibs/year) (Ibs/year) (Ibs/year) (Ibs/year) Benzene 26258 26258 1242 26258 1242 _ Toluene 33080 33080. 1596 33080 1596 Ethylbenzene 2886 2886 141 2886 141 Xylene - 16146 16146 796 16146 - 796 n -Hexane 9266 9266. 225 9266 225 224 TMP. 31 31 1 31 1 Section 06- Regulatory Summary Analysis Regulation 3, Parts A, 8 Regulation 7, Section 0511.0,2 Regulation 7, Section XVII.B.2:e Regulation 7, Section XII.H Regulation 8, Part E, MACT Subpart HH (Area) Regulation 8, Part E, MACT Subpart HH (Major). Regulation 8, Part E, MACT Subpart HHH (See regulatory applicability worksheet for detailed analysis) Source requires a permit Dehydrator is subject to Regulation 7, Section XVII, B,.0-3 The control device for this dehydrator is not subject to Regulation 7, Section XVIl.B.2.e Dehydrator Is subject no Regulation 7,Section XII.H The dehy unit meets the benzene exemption you have indicated that this facility Is not subjectto. Major Source requirements of MACT HH. You hove indicated that this facility is not subject to MACT HRH. Glycol Dehydrator Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements ' Was the extended wet gas sample used in the GlyCalc model/Process modelstespecfic and colected within a year of application submittal? if no,the permit will contain an "Initial Compliance" testing requirement to demonstrate compliance with emission limi Does the company request a control device effciencsgreater 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 If the company has requested a control device efficiencygreater than 95%, is a thermal oxidizer or regenerative thermal oxidizer being used to achieve it? If yes, the permit will contain a condition specifying the minimum combustion chamber temperature for the thermal oxidizer No (stile company using a thermal oxidizer AND requesting a minimum combustion chamber temperature lower than 1,400 degrees F? If yes, the permit will contain an "Initial Compliance" testing requirement AND a permtt condition specifying the minimum combustionchamber temperature for the thermal' oxidizer. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point N 020 Process It SCC Code 01 Uncontrolled Pollutant Emissions Factor Control % Units PM10 0.000 0.0 b/MMscf PM2.5 0.000 0.0 b/MMscf Sox 0.000 0.0 b/MMscf NOx 0.169 0.0 b/MMscf VOC 127.2 97.6 b/MMscf CO 0.768 0.0 b/MMscf Benzene 5.995 95.3 b/MMscf Toluene 7.553 95.2 b/MMscf Ethylbenzene 0.659 95.1 b/MMscf Xylene 3.686 95.1 b/MMscf n -Hexane 2116 97.6 b/MMscf 224 TMP 0.007 97.4 b/MMscf Dehydrator Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APENand Permit Requirements [Source 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 5 TPY, NOx greater than lO TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section ll.D.3)? 'You have" indicated that source is in the Non -Attainment Area NON -ATTAINMENT ,'- 1. Are uncontrolled emissions from any criteria pollutantsfrom this individual source greaterthan 1TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section ll.D.2)? Source requires a permit Colorado Regulation 7, Section XII.H 1. Is this glycol natural gas dehydrator located ih the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area (Reg 7, Section Xll;H.l and 2)? • 2. Is this glycol natural gas dehydrator located at an oil and gas exploration and production operation', natural gas compressor station, natural gas drip station or gas -processing plant (Reg 7 Section 3. Is the sum of actual uncontrolled emissions of VOC from any single dehydrator or group of dehydratorsat a single stationarysource equal to or greaterthan 15 tpy (Reg 7, Section XII.H.3.b)? 4. Are actual uncontrolled emissions of VOC from the individual glycol natural gas dehydrator equal to or greater than l tpy (Reg 7, Section XII.H3.a)?. Yes Dehydrator is subject to Regulation 7, Section XII.H Section XII.H — Emission Reductions from glycol natural gas dehydrators - MACT Analysis 1. Is the dehydrator located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final b. end user' (63.760(a)(3))? 2. Is the dehydrator located at a facility that is a major source for HAPs? Go to MACT NH Area Source Requirement section to determine MACT NH applicability Yes Yes 40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities Area Source Requirements 1. Is the dehydrator a triethylene glycol (TEG) dehydration unit (63.760(b((2))? Exemptions 2a. Isthe actual annual average flowrate of natural gusto the glycol dehydration unit less than 3.001747 MMscf per day (63.764(e)(1)(i)? 2b, Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (53.764(e)(1)(ii)? 3. Is the unit located inside of a UA plus offset and UC boundary area? 'The dehy unit meets the benzene exemption Subpart A, General provisions per §63.754 (a) Table 2 §63.765 - Emissions Control Standards Do Not Apply §63.773- Monitoring Standards Do Not Apply §63.774 - Recordkeeping §63.775 - Reporting Standards Do Not Apply Major Source Requirements 1. Does the facility have a facility -wide actual annual average natural gas throughput less than 0.55 MMscf/day AND a facility -wide actual annual average hydrocarbon liquid throughput less than 249.7 Small or Large Dehy Determination 2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.761)? 2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.761)? Small Dehy Requirements 3. Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.760(b)(1)(i)(B) and (C )? 4. For this small dehy, is a control device required to meet the BTEX emission limit given by the applicable equation? IYou have indicated that this facility is not subject to. Major Source requirements of MACT HH. Subpart A, General provisions per §63.764 (a) Table 2 §63.765 - Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting 40 CFR, Part 63, Subpart MACT HHH, Natural Gas Transmission and Storage Facilities 1 Is the facility wide actual annual average natural gas throughput less than 0.9994051 MMscf/day and glycol dehydrators the only HAP emission source (63.1270(f))? Small or Large Dehy Determination 2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 9.994051 MMscf per day (63.1270(b((2))? 26, Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.1270(b)(2))? Small Dehy Requirements 3. Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.1270(6)(2) and (3) )? 4. For this small dehy, is a control device required to meet the BTEX emission lime (standard?) given by the applicable equation? Yes You have indicated that this facility is not subject to MACT HHH. Subpart A, General provisions per §63.1274 (a) Table 2 §63.1275 - Emissions Control Standards §63.1281 -Control Equipment Standards §63.1283 - Inspection and Monitoring §63.1284 - Recordkeeping §63.1285 - Reporting Colorado Regulation 7, Section XVII.D 1. Is the dehydrator subject to an emissions control requirement under MACT HH or HHH (Regulation 7, Section XVII.8.5)? 2. Is this dehydrator located at a transmission/storage facility? 3. Is this dehydrator located at an oil and gas exploration and production operation, natural gas compressor station or gas processing plant (Reg 7, Section XVII.D.3)? 4. Was this glycol natural gas dehydrator constructed before May 1, 2015 (Reg 7 Section XVII.D.4.b)? If constructed prior to May 1, 2015, are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to or greater than b tons per year VOC or 2tpy VOC if the 4a. dehydrator.is located within 1,320 feet of a building unit or designated outside activity area (Reg 7, Section XVII.D.4.b)? 5. If constructed on or after May 1, 2015, are uncontrolled actual emissionsfrom a single glycol natural gas dehydrator equal to or greater than 2 tpy VOC (Regulation 7, Section XVII.D.4.a)? 'Dehydrator is subject to Regulation 7, Section XVII, 8, 0.3 Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.D.3 - Emissions Reduction Provisions Alternative Emissions Control (Optional Section( 6. Is this glycol natural gas dehydrator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? The control device for this dehydrator is not subject to Regulation 7, Section XVII.B.2.e Section XVII.B.2.e —Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend,' "may," "should," and 'can,' is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and 'Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. i No No Yes 021 Dehydrator Glycol Dehydrator Emissions Inventory (Facility AIRS ID:. Coon Plan Point Section 02- Equipment Description Details • Dehydrator Information Dehydrator Type: Make: Model: SeriaiNumber: Deslgn,Capacity: Recirculation Pump Information•. Number of Pumps Pump -Type Make: Model: Design/Max Recirculation Rate:. Dehydrator Equipment Flash Tank Reboiler Burner Stripping Gas Dehydrator Equipment Description lash tank,. - nd reboiler burner - - Stripping gas is injected into the reboller. One (1) Triethylene glycol )TEG) natural gas dehydration unit (Make: TBO, Model:. TO), Serial Number: TOD) with a design capacity of 30 MMscf per day. This emissions unit is equipped with 2 (Make: IGmray, Model: PV45020) gas driven glycol pump with a design capacity of 7.5 gallons per. minute. This dehydration unit is equipped with a will vent, flash tank, and reboller burner. Stripping gas is injected into the reboiler. Emission Control Dice Description: Emissions from the still vent are routed to the Enclosed Flare. Emissions from the flash tank are routed directly to the closed -loop system. Section 03- Processing Rate Information for Emissions Estimates Primary Emissions. Dehydrator Still Vent and Flash Tank (if present) Requested Permit Limit Throughput= MMscf per year Requested Monthly Throughput = 930 MMscf per month - Potential to Emit(PTE) Throughput = 10,950 MMscf per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Still Vent Control Condenser: Condenser emission reduction claimed: Primary control device: Primary control device operation: Secondary control device: Secondary control device operation:. Still Vent Gas Heating Value: Still Vent Waste Gas Vent Rate: Flash tank. Control Primary control device: Primary control device operation: Secondary control device: Secondary control device operation: Flash Tank Gas Heating Value Flash Tank Waste Gas Vent Rate: Section 04 -Emissions Factors & Methodologies Dehydrator Input Parameters Inlet Gas Pressure Inlet Gas Temperature Requested Glycol Recirculate Rate RequestedCo d777 °".t Tepe t re: Oegn g1W,?'C trol.Effic ency% hr/Yr , Requested TO Temp i'Control Efficiency.% hr/yr Btu/scf scfh hr/yr etu/scf scf ptlK deg F gpm Control Efficiency% STILL VENT Control Scenario Primary Secondary Pollutant Uncontrolled (lb/hr) Controlled (lb/hr) Controlled (lb/hr) VOC 11),,V 634835.1'. 3.174175 63.4835 Benzene 5.71'3 0.285865 5.7133 Toluene 7.5526 -- 0.36763. 7.3526 Ethylbenzene 0,bv.. 0.032615 0.6523 Xylenes ' 3.72'>1 "'. 0.186155 - 3.7231 n -Hexane '3:0441 0.052255 1.0451 224-TMP li. ,,,,,a,000 6 ,, % 0.00018 0.0036. FLASH TANK. Control See naria Primary Secondary Pollutant Uncontrolled (lb/hr) Controlled (lb/hr)- Controlled (lb/hr) VOC 'a`5:50 0itttllr{; 0 65.5038 Benzene 0.3319 0 0.3319 Toluene 032761;;;; 0 0,2761 Ethylbenzene ;;,0,p143... ,,- 0 0.0143 Xylenes 005rs��31: ;;; I' 0 0.0557 n -Hexane 2.094.:: ; 0 1.094 224 -IMP 5003D2V ;;:, 0 0.0035 Dry Gas Throughput Still Vent Primary Control: 10,950.0 MMscf/yr Still Vent Secondary Control: 0.0 MMscf/yr Waste Gas Combusted: -, Still Vent Primary Control: 36.5: MMscf/yr Still Vent Secondary Control: 0.0 MMscf/yr Dry Gas Throughput: - Flash Tank Primary Control: - 10,050.5' MMscf/yr Flash Tank Secondary Control: 0.0 MMscf/yr Waste Gas Combusted: Flash Tank:srimary Control: 0.0 MMscf/yr Flash Tank Secondary Control: QO MMscf/yr 13WE1092 dehy 3 flash tank off gas Calculation of High Heating Value with Know Gas Speciation assume volume %equals mole% Component HHV (etu/scf) mole % CO2 '0 3.72 N2' 0' 0.491 methane 1012 65.9 ethane 1783 14.9 propane 2557 9.01 isobutane 3354 0.989 o-bulsne 3369 3.01 ieopentane 4001 0.422 n -pentane 4009 0.041 Hexanes 4745 0 heptanes 5502.5 0.159 Octanes 6248.9 0.0334 Nonanes 6996.5 Dacana50 7742.9 Benzene 3741.8 - 0.0504 Toluene 4475 0.0356 Ethylbenzene 5222.2 0.0016 930.0 3.1 Glycol Dehydrator Emissions Inventory Pollutant. (Dry Gas Throughput) (Dry Gas Throughput) Emission Factor Source Xylem n-Hemne 22 TAW (HHV of n -C8) 5208 0.00622 4755.9 6248.9 0.15 0.000 99.420581 Toluene 6.10296 0.294104 0.53328 0.026092 Ethylbenze Xylene .02304 0.148924 n-Herane 224 TMP 28 0.041804. 0.00568 _ -0.000144 Still Vent Primary Control Device. Pollutant r Still Vent Secondary Control Device Pollutant Uncontrolled (Ib/MMBtu) (Waste Heat Combusted) Uncontrolled (Ib/MMscf) (Waste Gas Coco busted)' Uncontrolled Uncontrolled (Ib/MMBtu) (Ib/MMscf) (Waste Heat Combusted) (Waste Gas Combusted) PM10 PM2.5 0.0000 0.0000 0.0000 0.0000 0.0 SO NO CO Pollutant Flash Tank Primary Control Device Uncontrolled (Ib/MMBtu) (lb/MMs Uncontrolled ) (Waste Gas Corn busted) PM10 PM SO NO CO Emission Factor Source Emission Factor Source Emission Factor Source 0.0000 0.0000 0.0000 0 420.9800 Emission Factor Source Pollutant Flash Tank Secondary Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (Ib/MMscf) (Waste Heat Com busted) (Waste Gas Combusted) PM10 PM2.5 SOx NO CO 00 0.0000 0.0000 000 0.0000 Section 05 - Emissions Inventory Did operator request a buffer? Requested Buffer(%): .. Heating Value of Gas 1358 Btu/s hMp://.ivw.w.enggcyclopedia.corn/2011(09/headng-values-natural-gas/ Criteria Pollutants Potential to Emit . Uncontrolled (tans/yearl Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tans/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM10 PM2.5 SOx NOx CO VOC 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 0.8 0.8 0.8 0.8 0.8 133 3.6 3.6 3.6 3.6 3.6 605 565.0 565.0 13.9 FF505,0'I'. 13.9 2362 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions . Uncontrolled Controlled (Ibs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled • (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n•Hexane 224 TMP - 52956 52956 2502 52956 2502 66827 66827 3220 66627 3220 5839 5839 286 5839 286 33102 33102 1631 33102 1631 . 1.739 - 18739 458 18739 458 62 62 2 62 2 Section 06- Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.0,D Regulation 7, Section. XVI I.B2.e Regulation 7; Section XII.H Regulation 8, Part E, MACT Subpart HH (Area) Regulation 8, Part E, MACTSubpart HH (Major) Regulation 8, Part E, MACE' Subpart HHH (See regulatory applicability worksheet for detailed analysis) 13WE1092 dehy3. still. vent Calculation of.Hlgh Heating Value with Know Gas Speciation assume volume % equals mole % Component HHV (BtU/scf) ' mole% CO2 _ 0 1.23 N2 0 0.17' methane 1012 23.4 ethane 1783 5.1 propane 2557 3.42 isobutane 3354 0.415 n -butane 3369 1.35 isopentane 4001 0.208 n -pentane 4009 0.288 Hexanes 4745 0.414 heptanes 5502.5 0.19 Octanes 6248.9 0.35 Nonanes 6996.5 00100000 7742.9 Benzene 3741.8 0.666 Toluene 4475 0.726 Ethylbenzene 5222.2 0.0559 Xylenes .5208 0319 n -Hexane 4755.9 0.11 224 -IMP (OHS 6248.9 0.000361 38.412261 Heating Value 628.6248663 Btu/scf http://www.enggcyclopedia.com/2011/09/beating-values-natural-gas/ Source requires a permit Dehydrator is subject to Regulation 7, Section XVII, 0, 0.3 The control device far this dehydrator is not sUbject to Regulation 7, Section XVII.8.2.e Dehydrator is subject to Regulation 7, Section 011.11 Dehy,ia subject to area source MACT HH, per the requirements in 63.764(452) You have indicated that this facility Is not subject to Major Source requirements of MACT 00. You have indicated that th6 facility is not subjectto MACE' HHH. Glycol Dehydrator Emissions Inventory Section 0] Initial and Periodic Sampling and Testing Requirements • Was the extended wet gas sample used in the Gly0alc model/Process model site -specific and collected within a year of application submittal?-r,,.,y_,. ' If no, the permit will contain an "Initial Compliance" testing requirement to demonstrate compliance with emission limits Does the company request a control device efficiency greaterthan 95% for a flare or combustion device? - Ifyes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based an Inlet and outlet concentration sampling If the company has requested a control device efficiency greater than 95%, is a thermal oxidizer or regenerative thermal oxidizer being used to achieve it? If yes, the permit will contain a condition specifying the minimum combustion chamber temperature for the thermal oxidizer Is the company using a thermal oxidizer AND requesting a minimum combustion chamber temperature lower than 1,400 degrees F? If yes, the permit will contain an "Initial Compliance" testing requirement AND a permit condition specifying the minimum combustion chamber temperature for the thermal oxidizer. • No Section 09 - Inventory SCc Coding and Emissions Factors AIRS Point # 021 Process # 5CC Code 01 BEM Uncontrolled Pollutant Emissions Factor Control % Units PM10 0.000 0.0 b/MMscf PM2.5 0,000 0.0 b/MMscf 50x 0.000 0.0 b/MMscf 905 0.143 0.0 b/MMscf VOC 103.2 97.5 b/MMscf CO 0.650 0.0 b/MMscf Benzene 4.836 95.3 b/MMscf Toluene 6.103 95.2 b/MMscf Ethylhenzene 0.533 95.1 b/MMscf Xylene 3.023 95.1 b/MMscf n -Hexane 1.711 97.6 b/MMscf 224 TMP 0.00fi 97.5 b/MMscf Dehydrator Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Sourca is in the Non -Attainment Area ATTAINMENT - 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2TPY (Regulation 3, Part A, Section II.D.l.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B,Section 11.0.3)? You have indicatedthat source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, WOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.6.2)? source requires a permit Colorado Regulation 7, Section XII.H 1. Is this glycol natural gas dehydrator located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area (Reg 7,Section XII.H.1 and 2)? 2. Isth is glycol natural gas dehydrator located at an oil and gas exploration and production operation', natural gascompressor station, natural gas drip station or gas -processing plant (Reg 7 Section 3. Is the sum of actual uncontrolledemissions of VOC from any single dehydrator or group of dehydrators at a single stationary source equal to or greater than 15 tpy (Reg 7, Section XII:H.3.b)? 4. Are actual uncontrolled emissions of VOC from the individual glycol natural gas dehydrator equal to or greater than 1 tpy (Reg 7, Section XILH.3.a)? Dehydrator is subject to Regulation 7, Section XII.H - Section XII.H —Emission Reductions from glycol natural gas dehydrators MACT Analysis 1. Is the dehydrator located at an oil and natural gas production facility that meets either of the following criteria: a. Afacility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR A facility that processes, upgrades or stores natural gas prior to.the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final b. end userz (63.760(a)(3))? 2. Is the dehydrator located at a facility that is a major source for HAPs? IGo to MALT HH Area Source Requirement section to determine MACT HH applicability Yes Yes Yes 40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities Area Source Requirements - - 1. Is the -dehydrator a triethylene glycol (TEG) dehydration ant (63.760(b)(2))? Exemptions 2a. Is the acreal annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.764(e)(1)(i)? 2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphereless than 1,984.2 lb/yr (63.764(e)(1)(ii)? 3. Is the unit locatedinside of a UA plus offset and UC boundary area? Dehy is subject to area source-MACT HH, per the requirements in 63,764(d)(2) Subpart A, General provisions per §63.764 (a) Table 2 §63.765 - Emissions Control Standards Do Not Apply §63.773 -Monitoring Standards Do Not Apply §63.774-Recordkeeping. §63.775 -Reporting - Major Source Requirements Does the facility have a facility -wide actual annual average natural gas throughput less than 0.65 MMscf/day AND a facility -wide actual annual average hydrocarbon liquid throughput less than 249.7 Small or Large Delo/ Determination - - - 2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.761)7 2b. - Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.761)? Small Dehy Requirements 3.. Did construction of the small glycol dehydration unit commence on or before August. 23, 2011 (63.760(b)(1)(i)(B) and (C )? 4. For this small dehy, is a control device required to meet the BTEX emission limit given by the applicable equation? You have:indicated that this facility is not subject to Major Source: requirements of MACT HH. Subpart A, General provisions per §63.764 (a) Table 2 §63.765 - Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 -.Reporting.. 40 CFR, Part 63, Subpart MACT HHH, Natural Gas Transmission and Storage Facilities. - 1 Is the facility wide actual annual average natural gas throughput less than 0.9994051 MMscf/day and glycol dehydrators the only HAP emission source (63.1270(f))? Small or Large Dehy Determination - - 2a. _ Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 9.994051 MMscf per day (63.1270(b))2))? 2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.1270(b))2))? Small Dehy Requirements - - 3. Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.1270(6)(2) and (3) )? 4. For this small dehy,is a control device required to meet the BTEX emission limit (standard?) given by the applicable equation? Yes Youhaveindicated that this facility is not subject to MACT HHH. Subpart A, General provisions per §63.1274 (a) Table 2 §63.1275 - Emissions Control Standards 663.1281 -Control Equipment Standards §63.1283- Inspection and Monitoring §63.1284 - Recordkeeping §63.1285 - Reporting Colorado Regulation 7, Section XVII.D 1. Is the dehydrator subject toanemissions control requirement under MACT HH or HI -IF!. (Regulation 7, Section XVI I.B.5)? 2. Is this dehydrator located at a transmission/storage facility? 3. Is this dehydrator located at an oil and gas exploration and production operation, natural gas compressor station or gas processing plant (Reg 7, Section XVII.D.3)? 4. Was this glycol natural gas dehydrator constructed before May 1, 2015 (Reg 7 Section XVII.D.4.b)?. If constructed prior to May 1, 2015, are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to or greater than 6 tons per year VOC or 2 tpy VOC if the 4a. dehydrator is located within 1,320 feet of a building unit or designated outside activity area (Reg 7, Section XVII.D.4.6)? S. If constructed on or after May 1, 2015, are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to or greater than 2 tpy VOC (Regulation 7, Section XVII.D.4.a)? Dehydrator is subject to Regulation 7, Section XVII, B, D.3 - Section XVII.B— General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.D.3 - Emissions Reduction Provisions -. - Alternative Emissions Control (Optional Section) - 6. Is this glycol natural gas dehydrator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not. enclosed? The control device for this dehydrator is not subject to Regulation 7, Section XVII.8.2.e Section XVII.B.2.e-Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply toa 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 controllingrequirements 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 No Yes DECEIVED - ti Z018 Glycol Dehydration Unit APEN Form APCD-202 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 glycol dehydration (dehy) units only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.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: 13WE1092 AIRS ID Number: 123 / 9A09 /020 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Bonanza Creek Energy Operating Company, LLC Site Name: North Platte 14-36 Production Facility (COGCC #428456) Site Location: SWSW, 5N, 63W, 36 40.35193, -104.39019 Mailing Address: (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 Address' asoehner@bonanzacrk.com I 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-202 - Glycol Dehydration Unit APEN - Revision 7/2018 390117 1 I ACOLORADO F aM Permit Number: 13WE1092 AIRS ID Number: 123 /9AO9/ [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 O Change company name3 O Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership' O Other (describe below) - OR ▪ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-1O6) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Natural Gas Dehydration 12 MMscf/d TEG Unit with (2) Kimray PV21020 glycol pumps (1 for backup) Company equipment Identification No. (optional): DEHY-02 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 03/2019 ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any NAAQS nonattainment area? hours/day Is this unit located at a stationary source that is considered a Major Source of (HAP) Emissions? Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 days/week Yes Yes weeks/year No No COLORADO '2 L₹la�� maun r rneuo e�:� Permit Number: 13WE1092 AIRS ID Number: 123 /9Ac9/ [Leave blank unless APCD has already assigned a permit n and AIRS ID] Section 4 - Dehydration Unit Equipment Information Manufacturer: TBD Dehydrator Serial Number: .TBD Model Number: TBD Reboiler Rating: 1.00 MMBTU/hr hr Glycol Used: O Ethylene Glycol (EG) O DiEthylene Glycol (DEG) ▪ TriEthylene Glycol (TEG) Glycol Pump Drive: O Electric ❑✓ Gas If Gas, injection pump ratio: 0.080 / Acfm/gpm Pump Make and Model: Klmray PV21 020 Glycol Recirculation rate (gal/min): Max: 3.50 Lean Glycol Water Content: 1.5 Wt.% Requested: 3.50 # of pumps: 2 (1 backup) Dehydrator Gas Throughput: Design Capacity: 12 MMSCF/day Requested5: 4,380 MMSCF/year Actual: 4,380 MMSCF/year Inlet Gas: Pressure: 1000 psig Temperature: 120 °F lb/MMSCF ✓❑ Saturated Dry gas: 5.0 lb/MMSCF psig Temperature: 120 °F O NA Cold Separator: Pressure: psig Temperature: °F 0 NA Stripping Gas: (check one) O None O Flash Gas ❑✓ Dry Gas O Nitrogen Water Content: Wet Gas: Flash Tank: Pressure: 120 Flow Rate: 10.5 scfm Additional Required Information: ❑✓ Attach a Process Flow Diagram ❑✓ Attach GRI-GLYCalc 4.0 Input Report Et Aggregate Report (or equivalent simulation report/test results) • Attach the extended gas analysis (including BTEX Et n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 COLORADO 3 Permit Number: 13WE1092 AIRS ID Number: 123 /9Ace/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information eographicaiiCnordinates 'tide or UTM) 40.35193, -104.39019 4 'Hs4"`<+P"..F �l 0 0 cn"„ -,. •m - y r� y ilk i J`I t 's- , y . 3 F• �. __ �„ t�#5CF1�C, �2 $1P�h� � .•r p � �'o-. ,'".• +� x 4 Ode -0 n Learel 'irks s c " .v 'iu.5F 4 d � � � � a`,�.� '., [[��"' , ` ry v - ,•' ,b<, ' - a x� ^aj %r" G• G's s 4 A. ' s ��n `tv'q""" �r 'Nf- 'JWm lc -"'t� �Fjl ': r eI 4�w z� -,y; .� •) e[ TBD TBD 500 TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward O Horizontal O Downward ❑ Other (describe): O Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): TBD ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. O Condenser: Used for control of: Type: Make/Model: Maximum Temp: °F Average Temp: Requested Control Efficiency: % °F O VRU: Used for control of: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed: % ❑ Combustion Device: Used for control of: still vent Rating: 1.2 Type: ECD MMBtu/hr Make/Model: TBD Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 % Minimum Temperature: N/A °F Waste Gas Heat Content: 702 Btu/scf Constant Pilot Light: ❑✓ Yes O No Pilot Burner Rating: TBD MMBtu/hr Closed 0 Loop System: Used for control of: Flash Tank Description: Flash vapors are sent to the facility inlet. As a backup the vapors are sent to the fuel system System Downtime: 0 % ❑ Other: Used for control of: Description: Requested Control Efficiency: COLORADO Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 Permit Number: 13WE 1092 AIRS ID Number: 123 /9A../ [Leave blank unless APCD has already assigned a permit ., and AIRS ID] Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): PM lverall Requested ntrol Efficienc reduction.in emissions) SOX NO. CO VOC HAPs Other: ECD > 'CACL� ECD 1ZECyC (.E -05%- 9.14 (1 05%- From what year is the following reported actual annual emissions data? N/A Pollutant PM Uncontrolled Basis 40.0 ug/L AP -42 N/A <0.001 Criteria Pollutant Emissions Inventory Source (AP -42, Mfg., etc Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/ year) nested Annual,Permi mission Limit(s)5,, Uncontrolled Emissions (tons/year) N/A Controlled Emissions,. (tons/year) <0.001 SOx <0.001 lb/MMBtu AP -42 N/A <0.001 N/A <0.001 NO. 0.068 lb/MMBtu AP -42 N/A 0.26 N/A 0.26 CO 0.370 lb/MMBtu AP -42 N/A 2.03 N/A 2.03 VOC 61.96 lb/MMscf GRI-Glycalc 4.0 135.CD 6.78 135.68 6.78 Benzene Toluene Non -Criteria Reportable Pollutant Emissions Chemical Abstract' Service (CAS;) Number Emission'' Facto Uncontrolled Basis lb/MMscf GRI-Glycalc 4.0 �ctualAnnual! Emissions"'; ncontrollei, Emissions s_ (poundslyearj Z51a 1,242.0 71432 S 108883 ! 1gS,'5 1 7.29• lb/MMscf GRI-Glycalc 4.0 ,C39.001,(� 31,010 10 33 Q$v 1,595.6 Ethylbenzene Xylene n -Hexane 2,2,4- Trimethylpentane Other: 100414 0. 1330207 3 110543 Z, 540841 0 469 ,`51- 111f t -e8 o 004' Ib/MMscf lb/MMscf lb/MMscf lb/MMscf GRI-Glycalc 4.0 GRI-Glycalc 4.0 GRI-Glycalc 4.0 GRI-Glycalc 4.0 ',825.84 Z 15,013.201,1 4,583.00 15.18 , 141.2 (4t 795.6 MA, 225.2 3 0.80 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. Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 AW,COLORADO 5 NTT C [ .:h9P+neH- Permit Number: 13WE1092 AIRS ID Number: 123 /9Ac9/ [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 8 Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. Signature of Legally Authorized Person (not a vendor or consultant) Date Alisson Soehner Environmental Engineer, Air Quality Name (print) Title Check the appropriate box to request a copy of the: 0✓ Draft permit prior to issuance 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-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.Rov/cdphe/apcd Form APCD-202 —Glycol Dehydration Unit APEN - Revision 7/2018 Alin COLORADO '. FWtp•.t G+�119NTenl Glycol Dehydration Unit APEN Form APCD-202 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 glycol dehydration (dehy) units only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.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: 13WE1092 AIRS ID Number: 123 / 9AC9 / 02I [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Bonanza Creek Energy Operating Company, LLC Site Name: North Platte Production Facility (COGCC #428456) Site Location: SWSW, 5N, 63W, 36 40.35193, -104.39019 Mailing Address: (Include Zip Code) 410 17th Street, Suite 1400 Denver CO, 80202 a/t Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address'-: Alisson Soehner (303) 803-1752 asoehner@bonanzacrk.com Use the full, legal company name registered with the Colorado Secretary of State. This is the,company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 390118 COLORADO 1 I „tiff( - Haman i ,,, Permit Number: 1 3W 1092 AIRS ID Number: 123 / 9AC9 / [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 O Change company name3 O Add point to existing permit ❑ Change permit limit O Transfer of ownership4 O Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 General Information General description of equipment and purpose: Natural Gas Dehydration 30 MMscf/d TEG Unit with (2) Kimray PV45020 glycol pumps (1 for backup) Company equipment Identification No. (optional): DEHY-03 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 03/2019 ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any NAAQS nonattainment area? hours/day Is this unit located at a stationary source that is considered a Major Source of (HAP) Emissions? Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 days/week Yes Yes weeks/year No No COLORADO 2j Permit Number: 13WE 1092 AIRS ID Number: 123 '' [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Dehydration Unit Equipment Information Manufacturer: TBD Dehydrator Serial Number: Glycol Used: TBD Model Number: TBD Reboiler Rating: 1.50 MMBTU/hr hr O Ethylene Glycol (EG) O DiEthylene Glycol (DEG) ❑Q TriEthylene Glycol (TEG) Glycol Pump Drive: O Electric ❑✓ Gas If Gas, injection pump ratio: Pump Make and Model: Klmray PV45020 0.080 / Glycol Recirculation rate (gal/min): Lean Glycol Water Content: Max: 7.5 1.5 Wt.% Requested: 7.0 Acfm/gpm # of pumps: 2 (1 backup) Dehydrator Gas Throughput: Design Capacity: 30 MMSCF/day Requested5: 10,950 MMSCF/year Actual: 10,950 MMSCF/year Inlet Gas: Pressure: 1 000 psig Water Content: Wet Gas: lb/MMSCF Flash Tank: Pressure: 120 psig Cold Separator: Pressure: psig Stripping Gas: (check one) ❑ None ❑ Flash Gas ❑✓ Dry Gas ❑ Nitrogen scfm Flow Rate: 22.5 Temperature: 0 Saturated Temperature: Temperature: 120 °F Dry gas: 5.0 lb/MMSCF 120 °F O NA °F 0 NA Additional Required Information: 0 Attach a Process Flow Diagram ❑✓ Attach GRI-GLYCalc 4.0 Input Report Et Aggregate Report (or equivalent simulation report/test results) ❑✓ Attach the extended gas analysis (including BTEX Et n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 3 1 A.COLORADO mop Permit Number: 13WE1092 E 1092 AIRS ID Number: 123 /9Ac9 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Ci9rdmates (Latitude/Longitude or UTM) 40.35193, -104.39019 Jperator f �� aC C flj O Uucharge He ght Above Ground Level '.te Temp F) {.t±r.,-k Flow a (ACFM) ` Velocity (fthec) ECD 03-04 TBD 500 TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward 0 Horizontal O Downward ❑ Other (describe): O Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): 48 ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. 0 Condenser: Used for control of: Type: Make/Model: Maximum Temp: °F Average Temp: Requested Control Efficiency: % °F ❑ VRU: Used for control of: Size: Requested Control Efficiency: Make/Model: % VRU Downtime or Bypassed: % ❑✓ Device: Combustion Used for control of: Still Vent Rating: 2.7 Type: ECD MMBtu/hr Make/Model: TBD Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A F Waste Gas Heat Content: 633 Btu/scf Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: TBD MMBtu/hr Closed ❑✓ Loop System: Used for control of: Flash Tank Description: Flash vapors are sent to the facility inlet. As a backup the vapors are sent to the fuel system. System Downtime: 0 % O Other: Used for control of: Description: Requested Control Efficiency: Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 +� COLORADO 4 I . Ha4 ; e ;. Permit Number: 13WE1092 AIRS ID Number: 123 / 9AC9 / PM 40.0 PM [Leave blank unless APCD has already assigned a permit n and AIRS ID] Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table overall (or combined) control efficiency (% reduction): Description of Control Meth�od(s can be used to state the Overall Requested Control Efficiency (% reductionin emissions) SOX NO. CO VOC HAPs Other: ECD R,CZ, „�CLe.' ECD k RCt.VC i,u'- 0a%. ��tio -05%.45,3 Pp From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Emission Factor Actual Annual Emissions Requested Annual Permi Emission Limit(s)5"..;' Uncontrolled Basis ug/L Source (AP -42,' Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions§ (tons/year) Uncontrolled Emissions (tons/year) Cont `rolled_ Emissions (tons/year) AP -42 N/A 0.3070 N/A 0.307 SOX <0.001 Ib/MMBtu AP -42 N/A <0.001 N/A <0.001 NO. 0.068 lb/MMBtu AP -42 N/A 0.4997 N/A 0.4997 CO 0.310 lb/MMBtu AP -42 N/A 2.2779 N/A 2.2779 VOC 50.7868 Ib/MMscf GRI-Glycalc 4.0 -2.70 76 13.9029 —217-805-76"" 13.9029 1O3, ► 9 SLS. o SLs, o Benzene heroical Name Non -Criteria Reportable Pollutant Emissions Inventory Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emission Uncontrolled Basis lb/MMscf GRI-Glycalc 4.0 Uncontrolled Emissions'. poundslyear) ontrolled missions§ (pounds/ year) Toluene 71432 '4 108883 6 54 4.3886- I I 6.2399 lb/MMscf GRI-Glycalc 4.0 64,018.20 64,100.90 we ACS1,0 2,502.40 8L}3,220.40 8 3'l 285.80 Ethylbenzene 100414 0, 54 0.6579 43 3.1717. lb/MMscf GRI-Glycalc 4.0 5,71460 7 Xylene 1330207 3, lb/MMscf GRI-Glycalc 4.0 26,611.8033 0,155.00 16 In, 1,630.80 n -Hexane 110543 1, '}43.37488 lb/MMscf GRI-Glycalc 4.0 l'jq 457.8 2,2,4- Trimethylpentane 540841 0, 0 -0.0030- Ib/MMscf GRI-Glycalc 4.0 344O Z 1.6 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. Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 pp COLORADO 5 I L� nt al Put. Permit Number: 13WE1092 AIRS ID Number: 123 / 9AC9 / [Leave blank unless APCD has already assigned a permit ; and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. Signature of Legally Authorized Person (not a vendor or consultant) Date Alisson Soehner Environmental Engineer, Air Quality Name (print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 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: 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: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 A COLORADO 6 I "` Depart -rams. 93t Fnwisontment Hello