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HomeMy WebLinkAbout20191447.tiffCOLORADO Department of Public Health Et Environment 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 April 5, 2019 Dear Sir or Madam: RECEIVED APR 1 1 2019 WELD COUNTY COMMISSIONERS On April 11, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Bonanza Creek Energy Operating Company LLC - Mustang 42-34 Production Facility. 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 &t 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 %bl.% c. Rekx cc'Ptast4i€.R C lco /I1/1q y�ul>g 2019-1447 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Bonanza Creek Energy Operating Company LLC - Mustang 42-34 Production Facility - Weld County Notice Period Begins: April 11, 2019 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Bonanza Creek Energy Operating Company LLC Facility: Mustang 42-34 Production Facility Well Production Facility SENE Quadrant of Section 34, Township T4N, Range 63W Weld County The proposed project or activity is as follows: The applicant is seeking to permit a new oil and gas production facility located within the eight -hour (8 -hr) Ozone Control Area of Weld County. The facility currently produces both oil and natural gas from the Mustang V41-34-33XRLNB well. Emission points associated with this permit include Condensate Tanks, Produced Water Tanks, and natural gas venting. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE0938.CP1 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: James Ricci Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO 1 I A';�k Y.+atiLb£9vJfi'1nR1PT[ Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: James Ricci Package #: 386614 Received Date: 8/17/2018 Review Start Date: 1/23/2019 Section 01- Facility Information Company Name: Bonanza Creek Energy Operating Company LLC '. County AIRS ID: 123 Plant AIRS ID: 9FE9 Facility Name: Mustang 42-34 Production Facility (COGCC# 453242) Location: SENE Quadrant of Section 34, Township T4N, Range 63W County: Weld County Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? ❑ Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Quadrant Section Township Range SENE 34 T4N 63 Particulate Matter (PM) 2 Ozone (NOx &VOC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 002 Condensate Tank CNDTK-01, 02, 03 Yes 18WE0938.CP1 1 Yes ,Permit Initial f Issuance 003 Produced Water Tank PWT-01 w Yes 18WE0938.CP1 1 y Permit Initial Issuance 004 SeparatorVentingYes 18WE0938.CP1 1 Yes Permit Initial Issuance Section 03 - Description of Project Bonanza Creek Energy Operating Company LIC (Bonanza Creek) has requested to permit the Mustang 42-34 Production Facility (COGCC# 453242). This facility is a new oil and gas production facility located within the eight hour (8 -hr) Ozone Control Area of Weld County. The facility currently produces both oil and natural gas from the Mustang V41-34-33XRLNB well. Gas and oil produced from the well is processed through a high pressure three-phase separator where oil and water are separated from the natural gas. Due to lack of pipeline infrastructure in the area, the gas from the separator is sent to an enclosed combustor with a vendor guaranteed destruction efficiency of 98% or higher (Emission Point 004). The oil and water are sent to their respective tanks before being trucked from the facility (Emission Points 2 and 3). Truck loading vapors are returned to the condensate tanks via vapor return lines and then sent to the enclosed combustor for control Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? N If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Yes SO2 NOx CO VOC PM2.5 PM10 TSP HAPs SO2 MEd IEM No NOx CO r ❑ VOC PM2.5 PM10 TSP HAPs ❑ ❑ Condensate Storage Tank(s) Emissions Inventory ' 002 Condensate Tank Facility AIRS ID: 123 ' 9FE9: ' County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit"'' Three N500$arrel fixed roof storage vessels used to store condensate Description: Emission Control Device 1) 96 crimson CE 100 Description: .._ Requested Overall VOC & HAP Control 98" Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = 194,910 Barrels (bbl) per year Requested Permit Limit Throughput = 233,892 Barrels (bbl) per year Requested MonthlyThroughput = 19865 Barrels (bbl) per month Actual Condensate Throughput While Emissions Controls Operating = 194,910 Barrels (hbl) per year Potential to Emit (PTE) Condensate Throughput = 233,892 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= 2674Btu/scf Volume of waste gas emitted per BBL of liquid 77.2 .. produced= ' �' scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = From ProMax, Avg W&B and Flash ProMax v Pilot Light 40,263 48,316 MMBTU per year MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 48,316 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Pollutant Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Condensate Throughput) 0.04 wt;:,.. 0.04 .^ 0,00 ' ,p (Condensate Throughput) 0.001 0.001 0.000 0.000 0.007 0.000 Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (waste heat combusted) (lb/bbl) ' 0.0075 --' 0.0073 f' 0.0680 (Condensate Throughput) 0.0015 0.0015 0.0140 0.0640 Emission Factor Source Emission Factor Source Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) VOC PM10 PM2.5 N Ox CO 959.8 799.8 16.0 9599 19.2 3261 0.2 0.2 0.2 0.2 0.2 31 0.2 0.2 0.2 0.2 0.2 31 1.6 1.4 1.4 1.6 1.6 279 7.5 6.2 6.2 7.5 7.5 1272 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224TMP 9989 8324 166 9989 200 10326 8605 172 10326 207 133S 1112 22 1335 27 3528 2940 59 3528 71 79389 66158 1323 79389 1588 381 318 6 381 8 en 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XI I.C-F Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section 011.0 Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, 0, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 5, Part A, NSPS Subpart 0000 Storage Tank is not subject to NIPS 0000 Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) 2 of 12 C:\Users\jaricci\Desktop\18W E0938.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it maybe appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 -Technical Analysis Notes e Mustang U 22 facility on S117/2018 and analyzed by Air Pollution Testing, Inc on 5/18/2018. Since this sample was not taken from the facility being permitted, initial collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or nh this application. d Lab Analysis), Gas (Raw Gas Lab Analysis) and Water (Assuming 100% water) were all inputted into the ProMax model as inputs Using these three inputs, ProMzx modeled the Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 002 Process # SCC Code 01 Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.04 0 lb/1,000 gallons condensate throughput PM2.5 0.04 0 lb/1,000 gallons condensate throughput, NOx 0.33 0 lb/1,000 gallons condensate throughput VOC 195.4 98 lb/1,000 gallons condensate throughput CO 1.52 0 lb/1,000 gallons condensate throughput Benzene 1.02 98 lb/1,000 gallons condensate throughput Toluene 1.05 98 lb/1,000 gallons condensate throughput Ethylbenzene 0.14 98 lb/1,000 gallons condensate throughput Xylene 0.36 98 lb/1,000 gallons condensate throughput n -Hexane 8.08 98 lb/1,000 gallons condensate throughput. 224 TMP 0.04 98 lb/1,000 gallons condensate throughput 3 of 12 Cl\Users\jaricci\Desktop \ 18WE0938.CP1.xlsm Condensate Tank Regulatory Analysts Worksheet Colorado Regulation 3 Parts A and B -ADEN and Permit Requirements 'Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual sourcegreaterthan 2 TP?(Regulation 3, Part A, Section Il.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2for additional guidance on grandfather applicability)? 3. Are totalfMOlit uncontrolled VOC emissions :reaterthen5TPY, NOxu eater than lO TPY or CO emissions ; rester than IOTPY R;ulation 3, Part 9 Section 11.03? You have Indicated that source Is In the Mon -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any crkede pollutants from this individual source greater than E TPY (Regulation 3, Part A, Section B.D.l.e)? 2. Is the construction date (service date) prlorto 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissionsgreeterthan 2 TPY. NOxgreaterthen 5TPY or CO emissions greater than lO TPY (Regulation 3, Part 8, Section 11.02)? 'Source requires a permit Colorado Regulation 7, Section 011.0-F 1. Is this storage tank located in the 8 -hr ozone control area or any atone non -attainment area orattelnment/maintenance area? 2. Is this storage tank located at an ail and gas exploration and production operation', natural gas compressor station or natural gas drip station? 3. Is this storagetank located upstream of a natural gas processing plant? Storage tank is subject to Regulation 7, Section 101.C -F Section IOI.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage Section K11.02 —Emission Estimation Procedures Section 011.0 —Emissions Control Requirements Section1(11.6— Section KII.F—Recordkeeping and Reporting Colorado Regulation 7, section 201.0 1. Is this storage tank located In the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tanklocated at a natural gas processing plant? 3. Does this storage tank exhibit "Flash" (e.g. storing non-stabillzed liquids) emissions and have uncontrolled actual emissions greaterthan orequal to tons peryearVOC? (Storage Tank is not sub(ectto Regulation 7, Section 011.1 Section %11.02- Emissions Control Requirements Section KII.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage Section %11.02 —Emission Estimation Procedures Colorado Regulation 7. Section 10111 1. Is this tank located at a transmission/storage facility? 2. Is the condensate storagetank' located at an oil and gas exploration and production operation, well production facility", natural gas compressor station' or natural gas processing plant? 3. Is this condensate storage tank a feed roofst0rage tank? 4. Are uncommlled actual emissions of this storage tankequal to orgreaterthan 6 tons per year VOC? 'Storage tank Is subject to Regulation 7, Section KVII, 0, C.1 A 0.3 Section lMl.n -General Provisions forAlr Pollution Control Equipment and Prevention of Emissions Section IMI.C.1 - Emissions Control and Monitoring Provisions Section oOts.C3-Recordkeeping Requirements S. Does the condensate storage tank contain only "stabilized"liquids? 'Storage tank is subject to Regulation 7, Section IMI.C.2 Section 0VII.C.2 - Capture and Monkodng for Storage Ta nks fitted with Air Pollution Control Equipment 40 CFR Pert 60. Subpart Mr, Standards of Performance for Volatile Organic Liauid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (ma) [^472 Bets)? 2. Does the storage vessel meet the following exemption in 60.Illb(d)(4)? a. Does the vessel has a design capacity less then or equal to 1,569.874m3 ['10,000 BBL] used for petroleum" or condensate stored,processed, or treated prior to custody transfer' as defined in 60.11167 3. Was this condensate storage to nk constructed, reconstructed, or modified (see definitions 40 CFR, 602) afterlu ly 23, 1984? 4. Does thetank meet the definition of"storage vessera in 60.111b7 S. Does the storage vessel stom a"volatile organic liquid (VOL)" as defined in 00.11167 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate In excess 01 204.9 kPa ('29.7 psi) and without emissions to the atmosphere (00.110b(d)(2))?; or b. The design capacity is greater than or equal to 151 ma ['950 06L1'and stores a liquid with a maximum true vapor pressure less than 35 hOe (60.110b(b))T or c. The design capacity is greater than or equal to 75 Ma (1472 BBL] 'Artless than 151 ma ('950 BBL) and stores a liquid with a maximum true vapor pressures less than 15.0 kPa(60.110b(b)(? 'Storage Tank Is not subject to NSPS Kb Subpart A, General Provisions 4601126 -Emissions control Standards for VOL 4601136-Testingand Procedures - §60.115b -Reporting and Recordkeeping Requirements §60.116b- Monitoring of Operations 40 CFR, Parte°, Subpart0000. Standards of Performance far Crude On and Natural Gas Production,Traeamission and Distribution 1. Is this condensate storage vessel located ate facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this condensate storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tom per year? 4. Does the rnndensatertoragevessel meet the definition of .storage vessel"' per 60.5430? 5. Is the storage vessel subject to and controlled In accordance with requirementsforstora a vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH? 'Storage Tank Is notsubiect to NSPS 0000 Subpart A, General Provisions per 4605425 Table 3 460,5395- Emissions Control Standards for VOC 960.5413 -Testing and Procedures §60.5393(8) -Notification, Reporting and Recordkeeping Requirements 4605416(c) -Cover and Closed Vent System Monitoring Requirements 4605617 -Control Device Monitoring Requirements (Note: If a storage vessel in previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, It should remain subject to NSPS 0000 per 6o.536S(e)(2) even If potential VOC emissions drop below 6 tons per year] 40 CFR. Part 63. Subvert MAR NH. Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production fadlitythat meers either ofthefollowing criteria: a. Afacility thatprocesses, upgrades or stores hydrocarbon llqukl°(63.760(a)(2));OR b. Afacility that processes, upgrades or stores natural gas prinrto the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end usei' (63.700(a((3))? 2. Is the tank located at a facility that is major for HAPs? 3. Does the tank meet the definition of "storage vessel"° in 63.761? 4. Do. thetank meet the definition of°storage vessel with the patentialforflash emissions' per63.761? 5. Is the tank subject to control requirements under40 CFR Part 60, Subpart Kb or Subpart 0000? 'Storage Tank is not subject to MAR HH Subpart A, General provisions per 463.764 (a) Table 2 §63.766- Emissions Control Standards §63.773 -Monitoring 463.774- Recordkeeping 463.775 -Reporting RACT Review RACE review Is required if Regulation 7 does not apply AND If the tank is In the non -attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a role 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„ ifs 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 intendedto describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legallybindng requirements in and of itself. Yes Yes Yes No No Yes SSW.: ragia Yes 'Yes I Produced Water Storage Tank(s) Emissions Inventory 003 Produced Water Tank Facility AIRs ID: -x128 .. 9FE9 " ...'003,." County Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Three (1) 500 barrel fixed roof storage vessels used to store produced water Description: . .. '.ten :•Zl;;n ,: °-.., ,. Emission Control Device One (1) 96" Crimson CE 1000 Enclosed Combustor Description: Requested Overall VOC & HAP Control 95 Efficiency %: Section 03- Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = Requested Permit Limit Throughput = 124,100 148,920 Barrels (bbl) per year Requested Monthly Throughput= 12648 Barrels (bbl) per month '4 Barrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating = Potential to Emit (PTE) Produced Water Throughput= 6,420 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 1496 Btu/scf Volume of waste gas emitted per BBL of liquids produced = z. � scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 6,684 MMBTU per year 8,020 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 8,020 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Produced Water Tank Pollutant Uncontrolled Controlled (Ib/bbl) (Ib/bbl) (Produced Water Throughput) (Produced Water Throughput) Emission Factor Source VOC 0.01 Benzene Toluene 0.00035 0.000 0.000 0.000 0.001 0.000 Control Device Ethylbenzene Xylene n -Hexane 224 TMP 0.022 Pollutant Uncontrolled Uncontrolled (Ib/MMBtu) (Ib/bbl) (Produced (waste heat Water combusted) Throughput) PMIO PM2.5 0.0004 0.0004 0.0037 0.0167 0.0075 0.0680 .. NOx CO • •"0'.3100 'Ma) Section 05 - Emissions Inventory neludes Emission Factor Source flash) � Front itastr) _.Front Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) VOC PM10 PM2.5 NOx CO 19.5 16.3 0.8 19.5 1.0 166 0.0 0.0 0.0 0.0 0.0 5 0.0 0.0 0.0 0.0 0.0 5 0.3 0.2 0.2 0,3 0.3 46 L2 1.0 1.0 1.2 1.2 211 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224TMP 1042 869 43 1042 52 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 3276 2730 137 3276 164 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank Is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to HOPS 0000 (See regulatory applicability worksheet for detailed analysis) '424,100 : 5 of 12 C:\Users\jaricci\Desktop\18 W E0938.CP1.xlsm Produced Water Storage Tank(s) Emissions Inventory Section 07- Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. Does the company request a control device efficiency greater than 95%for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes State Approved emissions factors were used to calculate VOC, n' -Hexane, and Benzene emissions (PS Memo 09-02). State approved Heath Content and 09-02) to calculate secondary combustion emissions. Section 09- Inventory SCC Coding and Emissions Factors AIRS Point # 003 Process # SCC Code 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses -Water Ratios were ' also assumed (PS Memo Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.01 0 lb/1,000 gallons liquid throughput PM2.5 0.01 0 lb/1,000 gallons liquid throughput NOx 0.09 0 lb/1,000 gallons liquid throughput VOC 6.2 95 lb/1,000 gallons liquid throughput CO 0.40 0 lb/1,000 gallons liquid throughput Benzene 0.17 95 lb/1,000 gallons liquid throughput Toluene 0.00 95 lb/1,000 gallons liquid throughput Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput Xylene 0.00 95 lb/1,000 gallons liquid throughput n -Hexane 0.52 95 lb/1,000 gallons liquid throughput 224 TMP 0.00 95 Ib/1,000 gallons liquid throughput 6 of 12 C:\Users\jaricci\Desktop\ 18WE0938.CP1.xlsm Produced Water Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb. Colorado Reeulation 3 Parts A and B - APEN and Permit Requirements Source Is In the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY (Regulation 3, Part A, Section HALO? 2. Is the operator claiming less than 1% crude oil and Is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part3, Section ll.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 WY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.31? 'you have indicated that source is in the Non -Attainment Ares NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY (Regulation 3, Part A, Section ll.D.1.a)? 2. Is the operator claiming less than 1% crude oil and Is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section ll.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)7 'Source requires a permit Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this produced water storage tank' located at an ail and gas exploration and production operation , well production facility', natural gas compressor station' or natural gas processing plant? 3. Is this produced water storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions of this storage tank equal to or greater than 6 tons per year VOC7 'Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Section XVII.B— General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1- Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements S. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. 'Storage tank is subject to Regulation 7, Section XVII.C.2 Section XVII.C.2- Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60. Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this produced water storage vessel located at a facility In the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the Industry? 2. Was this produced water storage vessel constructed,reconstructed, or modified (see definitions 40CFR,60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions' from the Individual storage vessel greater than or equal to 6 tons per year? 4. Does this produced water storage vessel meet the definition of "storage vessel"' per 60.5430? 'Storage Tank is not subiect to N5P5 0000 Subpart A, General Provisions per §60.5425 Table 3 §60.5395- Emissions Control Standards for VOC §60.5413 - Testing and Procedures 460.5395(g) - Notification, Reporting and Recordkeeping Requirements 460.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417- Control Device Monitoring Requirements [Note: to storage vessel Is prevlously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year] RACT Review RACE review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACr requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and Is not legally enforceable. In the event of any contict between the language of this document and the language of the Clean Air Act„ Its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as 'recommend,' "may,' 'should," and "can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required' are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself No Yes Yes Yes Separator Venting Emissions Inventory 004 Separator Venting Facility AlRs ID: 123 County 9FE9 Plant 004 Point Section 02 - Equipment Description Details Vented Gas from One (1) Heated High Pressure Separator (1 @ 1.15 MMBtujhr) Detailed Emissions Unit Description: , One (1)66" Crimson CE 1030 Enclosed Combustor. . Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 -Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = ". 109.5 . MMscf per year Requested Permit Limit Throughput = :: '1005C. '° + MMscf per year Requested Monthly Throughput = MMscf per month Potential to Emit (PTE) Throughput = 109.5 MMscf per year Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: 1590 '' Btu/scf (HHV from Gas Analysis) Volume of waste gas emitted per BBL of 581,80. liquids throughput: scf/bbl Section 04 -Emissions Factors & Methodologies Description = A raw gas sample was taken at 75psig from the Mustang U-22 Facility on 5/17/2018. It was analyzed by Air Pollution Testing Inc on 5/ZS/2018 The applicant used %Mole from the gas analysis and the kndWn molecularyleights to' " convert %Moles (Weig t:The results were nearly identical to the -%Weights provided on the Gas Analysis. Because ofthis,.the applicants calculation method was accepted and can be seen below. Initial compliancewill be. required tatake a gassampfefrom the.fa, bei ng asthe sample pmvidedwas from adifferent, nearbyfacility: - _ MW Displacement Equation Ex = O * MW * Xx / C Weight % Mole % Molecular Weight Gas Weight Rb/16moll Oxygen/Argon 0.02 . 0.14 4.0026 0.0055 CO2 3.20 rC 2.03 , . 44.01 0.8916 N2 0.91 0,91. 28.013 0.2550 methane 33.97 '':59,03 16.041 9.4693 ethane 16.27 15.08 30.063 4.5343 propane 19.03 12,03 44.092 5.3049 isobutane 3.06 1,47 58.118 0.8542 n -butane 9.60 ' ```'4.60 'I 58.118 2.6751 isopentane 2.63 . 1.02 - 72.114 0.7330 n -pentane 3.49 1.35 72.114 0.9739 cyclopentane 0.32 :' 0.13 70.13 0.0881 n -Hexane 1.26 -' 0.41 86.18 0.3517 cyclohexane 0.35 -:' 0.12 84.16 0.0986 Otherhexanes 2.00 : ' 0.65 86.18 0.5585 heptanes 1.32 c,* ' , .. 0.37 100.21 0.3666 methylcyclohexane 0.46 0.13 '... 98.19 0.1277 224-TMP 0.00 -'. 0.00 114.23 0.0002 Benzene 0.17 . 0.06 '' 78.12 0.0487 Toluene 0,22 92.15 0.0601 Ethylbenzene 0.04 S 0.01 106.17 0.0105 Xylenes 0.12 b.03 .. 106.17 0.0343 Octanes+ 1.54 0.38 114.23 0.4300 Total VOC Wt % 100.00 100.00 27.9 45.62 27.9. b/Ib-mol Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) Emission Factor Source VOC 33551.7 671.0 Benzene Toluene 128.4 158.5 27.7 90.5 928.0 2.6 3.Z 0.6 1.8 18.6 0.0 Ethylbenzene Xylene n -Hexane 224 TMP 0.6 Pollutant Primary Control Device Uncontrolled (lb/MMBtu) (Waste Heat Combusted) (Gas Throughput) Uncontrolled lb/MMscf PM10 PM2.5 0.0075 11.847 11.847 0.935 SOx NOx 0.0006 -:r 0,0680 108.120 Emission Factor Source 8 of 12 C:\Users\jaricci\Desktop\18 W E0938.CP1.xlsm Separator Venting Emissions Inventory 9 of 12 C:\Users\jaricci\Desktop\ 18\%kE0938.CP1.xlsm Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM10 PM2.5 SOx NOx VOC CO 0.65 0.65 0.65 0.6 0.6 110 0.65 0.65 0.65 0.6 0.6 110 0.05 0.05 0.05 0.1 0.1 9 5.92 5.92 5.92 5.9 5.9 1006 1836.96 1836.96 36.74 1837.0 36.7 6241 26.99 26.99 26.99 27.0 27.0 4584 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 14061 14061 281 14061 281 17359 17359 347 17359 347 3037 3037 61 3037 61 9908 9908 198 9908 198 101613 101613 2032 101613 2032 66 66 1 66 1 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B, G Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. Source requires a permit Source is subject to Regulation 7, Section XVII.B.2, G The control device for this separator is not subject to Regulation 7, Section XVII.8.2.0 If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A 'Periodic Testing Requirement' to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? No If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greaterthan 95%for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answ 10 of 12 C:\Users\jaricci\Desktop\ 18WE0938.CP1.xlsm Separator Venting Emissions Inventory Section 08 -Technical Analysis Notes A raw gas sample was taken at 75psigfrom the Mustang U-22 Facility on 5/17/2018 It wesanalyzed by Air Pollution Testing Inc on 5/25/2018. The applicant used %Mole from thegas analysis and theknown molecular weights to convert %Mole to ffWeight. The results were nearly identical to the%Weights provided on the Gas Analysis. Because of this, the applicants calculation method ws accepted and can be seen below. Initial complancewll be required to take a gas sample from the facility being permitted as the sample provided was from a different, nearby facil ty. -- -- - A Gross Heating Value of 1590 BTU/scf was assumed in the calculations for the secondary combustion emissions,this value was provided on the Gas Analysis. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point It Process # SCC Code 004 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 11.85 0 lb/MMSCF PM2.5 11.85 0 Ib/MMSCF SOx 0.94 0 lb/MMSCF NOx 108.12 0 lb/MMSCF VOC 33551.70 98 lb/MMSCF CO 492.90 0 lb/MMSCF Benzene 128.41 98 Ib/MMSCF Toluene 158.53 98 Ib/MMSCF Ethylbenzene 27.73 98 Ib/MMSCF Xylene 90.48 98 Ib/MMSCF n -Hexane 927.97 98 lb/MMSCF 224 TMP 0.60 , 98 lb/MMSCF 11 of 12 C:\Users\ja rl cci\Desktop\18 W E0938.CP1.ilsm Separator Venting Regulatory Analysis Worksheet Re lation 3 Parts A and B -APEN and Permit Requirements Colorado ource is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TRY (Regulation 3, Part A, Section ll.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than SIP?, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.5.31? 'Not enough information NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section I I.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the 'greater than 2 TPY, NOR greater than 5TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section lI.D.2)? 'Source requires a permit Colorado Regulation 7, Settles XVII 1. Was the well newly constructed, hydraulically fractured, orrecompleted on or after August 1,2014? 'Source is sublectto Regulation 7, Section XVII.B.2, G Section XVII.B.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section) a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? 'The control device for this separator is not subject. 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. es of Division 11 Er Environment CONSTRUCTION PERMIT Permit number: 18WE0938 Date issued: Issued to: Issuance: 1 X Bonanza Creek Energy Operating Company LLC Facility Name: Plant AIRS ID: Physical Location: County: General Description: Mustang 42-34 Production Facility (COGCC# 453242) 123/9FE9 SENE Quadrant of Section 34, Township T4N, Range 63W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description CNDTK-01-03 002 Three (3) 500 barrel fixed roof storage vessels used to store condensate Enclosed Combustor PWT-01 003 One (1) 500 barrel fixed roof storage vessels used to store produced water Enclosed Combustor VENT 004 High Pressure Separator Enclosed Combustor 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, bar submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. CDPHE COLORADO Air Pollution Control Division Department of Public Health b Environment Page 1 of 12 2. 80) of the latter of commencement of operation with the conditions contained in this permit shall s the owner or operator's responsibility to self - Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit -self -certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. Point 004: 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 561.80 scf/bbl estimated in the permit application. 5. 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.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO CNDTK-01-03 002 -- 1.6 19.2 7.5 Point PWT-01 003 -- 0.3 1.0 1.2 Point VENT 004 -- 5.9 36.7 27.0 Point Note: See "Notes to Permit Holder" for information on used to calculate limits. Facility -wide emissions of each individual hazardous air tons per year. COLORADO Air Pollution Control Division Department' of Public Health b Environment emission factors and methods pollutant shall not exceed 8.0 Page 2 of 12 ous air pollutants shall not exceed 20.0 tons per limitati for hazardous air pollutants shall apply to all u is fa Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 8. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled CNDTK-01-03 002 Enclosed Combustor VOC and HAP PWT-01 003 Enclosed Combustor VOC and HAP VENT 004 Enclosed Combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit 002 Condensate throughput barrelb2 2CNDTK-O1-O3 barrels PWT-01 003 Produced water throughput 1 0 baarrelrrels VENT 004 Natural Gas Venting 109.5 MMSCF The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. Point 004: 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 COPHE COLORADO Air Pollution Control Division Department of Public Health 5 Environment Page 3 of 12 rocess limits contained in this permit and to s permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 11 The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. Points 002, 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, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 14. Points 002, 003, 004: 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. 15. Point 002, 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 for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. COLORADO Air Pollution Control Division Department of Pubic Health la Emaranment Page 4 of 12 16. ks cered by this permit are subject to the venting and ent v stem ("STEM") requirements of Regulation 17. Poi : 0era: a spar `or �,�vered this permit is subject to Regulation 7, Section .G. er A 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING &t MAINTENANCE REQUIREMENTS 18. Points 002, 003, 004: Upon startup of these points, the owner or operator shall 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.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 19. Point 002: 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 VOC 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. 20. Point 004: 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 VOCcontent (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). COLORADO Air Pollution Control Division Department' of Pubt!c Health b Environment Page 5 of 12 21. Poin , I 03, : T `caner a • r operator shall demonstrate compliance with e Method 22, 40 C.F.R. Part 60, Appendix A, to of visible emissions. "Visible Emissions" means perio• periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) 22. Point 002, 004 A source initial compliance test shall be conducted to measure the emission rate for volatile organic compounds (VOC) in order to demonstrate compliance with a minimum destruction efficiency of 98% for VOCs. The test shall determine the mass emission rates of volatile organic compounds at the inlet and outlet of the control device, which shall be used to determine the destruction efficiency during the test. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. (Regulation Number 3, Part B., Section III.G.3) Periodic Testing Requirements 23. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 24. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: COPHE 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 NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or COLORADO Air Pollution Control Division Department of Public Health 6 Environment Page 6 of 12 ation ust be modified; or fore ` e existing APEN expires. 25. '�ra l�� ; pruire ts (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 26. 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. 27. 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. 28. 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. 29. 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. 30. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 31. 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 COLORADO Air Pollution Control Division Department of Pate Health & EMI onment Page 7 of 12 is to be discontinued, the owner must notify the Nation of the permit. Upon notification, annual 32. • ati• arm ermi 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: DRAFT James Ricci Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Bonanza Creek Energy Operating Company LLC. Facility wide permit including condensate tanks, produces water tanks and venting at an EftP Facility in the non - attainment. COLORADO Air Pollution Control Division Department of Pubs Health b Environment Page 8 of 12 Notes ,t• Pe it a ,`lam: -r at :time � his p mit issuance: 1) Thqui-d tea p.' fee or the processing time for this permit. An invoice foiss er the -rmit is issued. The permit holder shall pay the i wi 3 o of t voice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https: / /www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 002 Benzene 71432 9989 200 Toluene 108883 10326 207 Ethylbenzene 100414 1335 27 Xylenes 1330207 3528 71 n -Hexane 110543 79389 1588 2,2,4-Trimethylpentane 540841 381 8 003 Benzene 71432 1042 52 n -Hexane 110543 3276 164 004 Benzene 71432 14061 281 Toluene 108883 17359 347 Ethylbenzene 100414 3037 61 Xylenes 1330207 9908 198 n -Hexane 110543 101613 2032 2,2,4-Trimethylpentane 540841 66 1 COLORADO Air Pollution Control Division Department of Public Health b [n ronment Page 9 of 12 ollut.z is in the table above with uncontrolled emission /yr) 'ire reportable and may result in annual emission fees lution E ission Notice. 5) issi his p t are based on the following emission factors: Point 002: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 1.40 x 10-2 1.40 x 10-2 AP -42 (Flares) CO 6.40 x 10.2 6.40 x 10.2 VOC 8.21 x 10° 1.64 x 10-1 ProMax 71432 Benzene 4.27 x 10-2 8.54 x 10-4 108883 Toluene 4.41 x 10-2 8.83 x 10-4 100414 Ethylbenzene 5.71 x 10-3 1.14 x 10-4 1330207 Xylene 1.51 x 10-2 3.02 x 10-4 110543 n -Hexane 3.39 x 10"1 6.79 x 10"3 540841 2,2,4-Trimethylpentane 1.63 x 10-3 3.26 x 10-5 Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency of 98%. Point 003: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 3.66 x 10"3 3.66 x 10-3 AP -42 (Flares) CO 1.67 x 10-2 1.67 x 10"2 VOC 2.62 x 10"t 1.31 x 10"2 CDPHE 71432 Benzene 7.00 x 10"3 3.50 x 10"4 110543 n -Hexane 2.20 x 10-2 1.10 x 10-3 Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency of 95%. COLORADO Air Pollution Control Division Department of Public t lealth b environmont Page 10 of 12 CAS # Pollutant Uncontrolled Emission Factors lb/MMSCF Controlled Emission Factors lb/MMSCF Source NOx 108.1 108.1 AP -42 (Flares) CO 492.9 492.9 VOC 33551.7 671.0 Extended Gas Analysis 71432 Benzene 128.4 2.6 108883 Toluene 158.5 3.2 100414 Ethylbenzene 27.7 0.6 1330207 Xylene 90.5 1.8 110543 n -Hexane 928.0 18.6 540841 2,2,4-Trimethylpentane 0.6 0.0 Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency of 98%. The emission factors listed above are based on modeled separator temperature of 110 °F and separator pressure of 75 psig. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five- year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) Point 002: This source is subject to 40 CFR, Part 60, Subpart 0000a - Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced after September 18, 2015 (See June 3, 2016 Federal Register posting - effective August 2, 2016.) This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available at the Office of the Federal Register website at: https: / /www.federalregister.gov/documents/2016/06/03/2016-11971 /oil -and - natural -gas -sector -emission -standards -for -new -reconstructed -and -modified -sources COLORADO Air Pollution Control Division DepartmerA of Pubes Health Er Environment Page 11 of 12 -. ca, Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, Toluene, Benzene, Total HAPs NANSR Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO. Air Pollution Control Division Department of Pubk Health & Environment Page 12 of 12 SV1pfr5PJ,oa See : cAiA,s\-a.e WPnaaM (t v'ie\ 02Jo /1O\1 Condensate Storage Tank(s) APEN Form APCD-205 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 tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.cotorado.00v/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: TBD' Q Q ibr'"[� 3 AIRS ID Number: 123 Iii FE I/ 00 2 [!� [Leave blank unless APCD has air ad./ „ssign.ed a pernsir and AIRS ID] Section 1 - Administrative Information Company Name: Bonanza Creek Energy Operating Company. LLC Site Name: Mustang 42-34 Production Facility (COGCC# 453242) Site Location: SENE S34 T4N R63W Mailing Address: (Include Zip Code) 410 17th Street, Suite 1400 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: Alisson Soehner (303) 803-1752 E -Mail Address2: Asoehner@bonanzacrk.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 386609 COLORADO Form APCD-2.05 - Condensate Storage Tank(s) APEN - Revision 7/2018 1 Permit Number: TBD AIRS ID Number: • 123 / / .[Leave blank. unless APCD has alreadyatready.assiczned a perm[ t' and AIRS IDS Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 0 GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment 0 Change company name3 ❑ Change permit limit 0 Transfer of ownership4 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on potential To Emit (PTE) Additional Info Et Notes: Initial E&P wellsite application 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: The tank battery will be used for condensate storage prior to it being trucked out. CNDTK-01, CNDTK-02, CDNTK-03 For new or reconstructed sources, the projected start-up date is: 05/19/2018 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 weeks/year 0 Exploration Et Production (EELP) site ❑ Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? IO Yes ■ No Are Flash Emissions anticipated from these storage tanks? 12 Yes ■ No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? Yes No p ■ If "yes", identify the stock tank gas -to -oil ratio: 0.0107 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)• 805 series rules? If so, submit Form APCD-105. Yes No O Areyoy requessin,2 ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissiors' b for /yr (per storage tank)? Yes No U O Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 2 COLORADO Permit Number: TBD AIRS ID Number: 123 I [Leave blank unless E•.PC:D has already assigned a permit # and AIRS ID; Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limits (bbl/year) Condensate Throughput: 194,910 233,892 From what year is the actual annual amount? Average API gravity of sales oil: 39.3 degrees ❑ Internal floating roof Tank design: El Fixed roof RVP of sales oil: 7.5 ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) CNDTK (3) 500 -bbl 1,500 4/2018 5/2018 Wells Serviced by this Storage Tank or Tank Battery6 (E&P Sites On y) API Number Name of Well Newly Reported Well 05 - 123 - 46001 Mustang V41-34-33XRLNB El ■ ■ ■ IN 5 Requested values will become permit limitations. Requested limits) should consider future growth. 6 The EEO' Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.271558/-104.416372 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) EC D-01 35 Indicate the direction of the stack outlet: (check one) D Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) 0 Circular ❑ Square/ rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): 96 Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 COLORADO 3 I Permit Number: TBD AIRS ID Number: 1 23 / [ eay,e blank unless APO has already assigned a permit A and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC. HAP Rating: 4 MMBtu/hr Type: Enclosed Combustor Make/Model: Crimson CE 1000 Requested Control Efficiency: 98 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Waste Gas Heat Content: Constant Pilot Light: ❑ Yes ❑ No Pilot Burner Rating: 2,452 N/A Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 75 psig Describe the separation process between the well and the storage tanks: The well produces into a single stage 3 -phase separator where condensate is separated out and routed to the condensate tank battery. COLORADO Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2010 Permit Number: TBD AIRS ID Number: 1 23 I [Leave blank unless /.PCD has already assi_ned e permit / and /dRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the biped) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECD 98 NOx CO HAPs ECD 98 Other: From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Tons/year) Controlled Emissions8 (Tons/year) Uncontrolled Emissions Tons/ ear (Tons/year) ) Controlled Emissions (Tons/ ear (Tons/year) VOC 6.3085 lb/bbl ProMax 4.0 614.79 12.30 737.76 14.76 NOx 0.068 Ib/MMBtu AP -42 N/A 1.00 N/A 1.20 CO 0.310 lb/MMBtu AP -42 N/A 4.54 N/A 5.4 - Non -Criteria Reportable Pollutant Emissions inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis- Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled Emissions8 (Pounds/year) Benzene 71432 0.0327 lb/bbl ProMax 4.0 6,372 128 Toluene 108883 0.0330 lb/bbl ProMax 4.0 6,428 130 Ethylbenzene 100414 0.0042 lb/bbl ProMax 4.0 814 18 Xylene 1330207 0.0110 lb/bbl ProMax 4.0 2,126 44 n -Hexane 110543 0.6133 lb/bbl ProMax 4.0 119,520 2,392 2,2,4 Trimethylpentane 540841 0.0014 lb/bbl ProMax4.0 262 6 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees wilt be based on actual controlled emissions reported. If source has not yet started operating, leave blank. ANI:FT COLORADO Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 5 I Permit Number: TBD MRS ID Number: 123 I [Leave blank unless APCD has thready assigned a permit and AIRS lDI Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and wilt be operated in full compliance with each condition of the applicable General Permit. z/i cot Signature of Legally Authorize rson (not a vendor or consultant) Alisson Soehner Name (print) Date Environmental Engineer, Air Quality Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN. is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 • Make check payate to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 6 IA C0lURnD3 APEN Addemdum Recieved 2/5/2019 Condensate Storage Tank(s) APEN Form APCD-205 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 tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 7` 23 / T'8� ( 'U, LL AIRS ID Number: [ r �`Lv [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: Mustang 42-34 Production Facility (COGCC# 453242) Site Location: SENE S34 T4N R63W Mailing Address: (Include Zip Code) 410 17th Street, Suite 1400 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address: Alisson Soehner (303) 803-1752 Asoehner@bonanzacrk.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-205 Condensate Storage Tank(s) APEN Revision 7/2018 ®mw COLORADO Permit Number: • • TBD AIRS ID Number: 123 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership4 O Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Initial E&P weilsite application 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: The tank battery will be used for condensate storage prior to It being trucked out. CNDTK-01, CNDTK-02, CDNTK-03 For new or reconstructed sources, the projected start-up date is: 05/19/2018 Normal Hours of Source Operation: 24 hours/day 7 Storage tank(s) located at: days/week 52 weeks/year ❑✓ Exploration Et Production (EEtP) site 0 Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? SI Yes ■ No Are Flash Emissions anticipated from these storage tanks? El Yes O No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? 0 Yes ■ No If "yes", identify the stock tank gas -to -oil ratio: 0.0136 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No • )0 Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No 0 ■ Form APCD-205 Condensate Storage Tank(s) APEN - Revision 7/2018 COLORADO litre"), -thin 2 11.94, FE. fi'Cl.IYf(1 Permit Number: TBD AIRc ID Number: 1 9'1 / / [Leave blank unless APCD has already assigned a permit ; and AIRS ID] Section 4 - Storage Tank(s) Information Condensate Throughput: Actual Annual Amount (bbl/year) 194,910 Requested Annual Permit Limits (bbl/year) 233,892 From what year is the actual annual amount? Average API gravity of sales oil: 40.3 degrees ❑ Internal floating roof Tank design: E Fixed roof RVP of sales oil: 7.5 ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) CNDTK (3) 500 -bbl 1,500 4/2018 5/2018 Wells Serviced by this Storage Tank or Tank Battery6 (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 46001 Mustang V41-34-33XRLNB ll ■ ■ ■ ■ 5 Requested values will become permit limitations. Requested limits) should consider future growth. 6 The EFtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.271558/-104.416372 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) EC D-01 35 Indicate the direction of the stack outlet: (check one) +❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) 0 Circular 0 Square/rectangle 0 Other (describe): 0 Upward with obstructing raincap Interior stack diameter (inches): 96 Interior stack width (inches): Interior stack depth (inches): Form APCD-205 Condensate Storave Tankis) APEN - Revision 7/2018 3 I IiINF COLORADO Permit Number: TBD AIRS ID Number: 123 I [Leave blank unless APCD has already assigned a permit rf and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC, HAP Rating: 5.52 Type: Enclosed Combustor Make/Model: Crimson CE 1000 MMBtu/hr hr Requested Control Efficiency: 98 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A o /0 Waste Gas Heat Content: 2,674 Btu/scf Constant Pilot Light: ✓❑ Yes El No Pilot Burner Rating: N/A MMBtu/hr O Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 75 psig Describe the separation process between the well and the storage tanks: The well produces into a single stage 3 -phase separator where condensate is separated out and routed to the condensate tank battery. Form APCD-205 Condensate Storage Tank(s) APEN - Revision 7/2018 COLORADO mr we 4I 1 N�bfrrrr Inc Permit Number: TBD AIRS ID Number; 123 / / [Leave blank unless APCD has already assigned a permit and AIRS ID] Section 8 - Emissions inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECD 98 NOx CO HAPs ECD 98 Other: From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Pollutant Emission Factor7 Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Tons/year) Controlled Emissions8 (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) VOC 8.2065 lb/bbl ProMax 4.0 799.76 16.00 959.72 19.20 NOx 0.068 lb/MMBtu AP -42 - N/A 1.38 N/A 1.65 CO 0.310 lb/MMBtu AP -42 N/A 6.26 N/A 7.49 Non -Criteria Reportable Pollutant Emissions Inventory Chemical - Emission Factor7 Actual Annual Emissions Chemical Name Abstract �) Service (CAS) Number Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled Emissions8 (Pounds/year) Benzene 71432 0.0428 lb/bbl ProMax 4.0 8,324 168 Toluene 108883 0.0442 lb/bbl ProMax 4.0 8,605 174 Ethylbenzene 100414 0.0058 lb/bbl ProMax4.0 1,112 24 Xylene 1330207 0.0151 lb/bbl ProMax 4.0 2,940 60 n -Hexane 110543 0.3395 lb/bbl ProMax4.0 66,158 1,324 2,2,4- 540841 0.0017 Ib/bbl ProMax 4.0 318 8 Trimethylpentane 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach condensate liquid Laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-2O5 Condensate Storage Tank(s) APEN - Revision 7/2018 ®V COLORADO Permit Number: TBD MRS ID Number: 1 %. / / !Leave blank unless APCD has already assigned a permit and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signature of Legally Authorized Person (not a vendor or consultant) Date Alisson Soehner Environmental Engineer, Air Quality Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 430D 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.Qov/cdphe/apcd Form APCD-205 Condensate Storage Tank(s) APE)) - Revision 7/2018 �V' COLORADO 6 SrSe,\•J, JtP �1 1T�}c�.�.h A L- 4c124Hih fe.Ce N ec�s O-(°, [ D\ Produced Water Storage Tank(s) APEN ® Form APCD-207 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 tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: vd6Oti AIRS ID Number: 123 /PAR/0©5 APCD Stationary Souri:es Leave thank unless APCD has aLe dy assicsmed _emit - and AIRS ID] Section 1 - Administrative Information Company Name: Bonanza Creek Energy Operating Company, LLC Site Name: Mustang 42-34 Production Facility (COGCC# 453242) Site Location: SENE S34 T4N R63W Mailing Address: (Include Zip Code) 410 17th Street, Suite 1400 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address2: Alisson Soehner (303) 803-1752 Asoehner@bonanzacrk.com 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-207 - Produced Water Storage Tank(s) APEN - Revision 7,1.'018 386610 ,i',„14.,„41C0L0RAD0 .1 I Permit Number: TBD AIRS ID Number: 123 / a blank iunis:s APCD has alre?.dpi assi?nied a permit 4 and AIR'S ID] Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP05 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. OR - • MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) OR ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: Initial E&P wellsite application 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Storage of produced water prior to being trucked out PWT-01 For new or reconstructed sources, the projected start-up date is: 5/19/2018 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 weeks/year ❑✓ Exploration Et Production (EU) site ❑ Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? Yes ❑ No ✓ Are Flash Emissions anticipated from these storage tanks? Yes ❑ No I Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? ❑ Yes No ✓ Do these,stocag� �tt�Tanks contain less than 1% by volume crude oil on an annual average basis? ❑ Yes No ✓ Are thes&'sfdragr#.tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. ❑ Yes No ,./ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? ❑ Yes No ✓ Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/20(8 2I COLORADO Permit Number: TBD AIRS ID Number: 123 / (Leave blank. unless APCD has atre.,,dv ac4 cined a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl /year) Requested Annual Permit Limits (bbl /year) Produced Water Throughput: 124,100 148,920 From what year is the actual annual amount? Tank design: ❑✓ Fixed roof ❑ Internal floating roof ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) PWT-01 (1) 500 -bbl 500 4/2018 5/2018 Wells Serviced by this Storage Tank or Tank Battery6 (E&P Sites On y) API Number Name of Well Newly Reported Well 05 - 123 -46001 Mustang V41-34-33XRLNB ✓ s Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.271558/-104.416372 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) ECD-01 35 Indicate the direction of the stack outlet: (check one) Ej Upward ❑Downward ❑ Horizontal Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) CI Circular Interior stack diameter (inches): 96 El Square/rectangle Interior stack width (inches): Interior stack depth (inches): El Other (describe): Form A?CD-2O7 - Produced Water Storage Tank(s) APEN - Revision 7/2018 � COLORADO 3I Permit Number: TBD AIRS ID Number: 123 / l� eave blank unless APCD has ahead`( assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor D Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC, HAP Rating: 4 MMBtu/hr Type: Enclosed Combustor Make/Model: Crimson CE 1000 Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 2,452 N/A Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (EftP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 75 psig Describe the separation process between the well and the storage tanks: The well produces to a single stage 3 -phase separator where produced water is separated out and routed to the produced water tank. Form APCD-207 - Produced `-fetter Storms Tank(s) APEN - Revision 7/2018 4i A OLORADO Permit Number: TBD MRS ID Number: 123 / PC " ] �!..9,;n _ICLe 5s ut�� i!3> cl(c:n;�`/ a551� �.:1 i �:'I"iT1�.= ., and AIRS {�? Section 8 --Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple,emission control methods were identified in Section 6, the following table can be used to state the verall (or combined) control efficiency (% reduction ): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECD 95 NOx CO HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/ ear) y Controlled Emissions8 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 0.2620 lb/bbl State EF 16.26 0.81 19.51 0.98 NOx 0.0009 lb/bbl State EF N/A 0.06 N/A 0.07 CO 0.0024 lb/bbl State EF N/A 0.15 N/A 0.18 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) g Uncontrolled Emissions (pounds/year) (pounds/ ear Controlled Emissions8 (pounds/year) Benzene 71432 0.0070 lb/bbl State EF 870 44 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0220 lb/bbl State EF 2,732 138 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-2O7 - Produced Water Storage Tank(s) APEN - Revision 7/2018 COLORADO 5 !MV Permit Number: TBD AIRS ID Number: 123 I [Leave blank unless APCD has already assigned a permit: 4 and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. cot' 45 Signature of Legally Authorizes rson (not a vendor or consultant) Date Alisson Soehner Environmental Engineer, Air Quality Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 6 I A COLORADO APEN Addemdum Recieved 2/5/2019 Produced Water Storage Tank(s) APEN - Form APCD-207 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 tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: `< y , AIRS �-30 E: 1 ��t-0 ? Number: ID 23 f�( l ��� [Leave blank unless APCD has already assigned a penniit r- and AIRS ID] Section 1 - Administrative Information Company Name: Bonanza Creek Energy Operating Company, LLC Site Name: Mustang 42-34 Production Facility (COGCC# 453242) Site Location: SENE S34 T4N R63W 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 Address2: Asoehner@bonanzacrk.com Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-2O7 Produced Water Storage Tank(s) APEN Revision 7/2018 • 1 I AV COLORADO Permit Number: •TBD AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit ii and AIRS ID] Section 2 - Requested Action NEW permit OR newly -reported emission source ✓❑ Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP05 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change in equipment ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: Initial E&P wellsite application 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Storage of produced water prior to being trucked out PWT-01 For new or reconstructed sources, the projected start-up date is: 5/19/2018 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 weeks/year ✓❑ Exploration & Production (EEtP) site ❑ Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? SI Yes ■ No Are Flash Emissions anticipated from these storage tanks? NI Yes ❑ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? ❑ Yes No IS Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ❑ Yes ✓ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. ❑ Yes No IS Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No ✓ • Form APCD-207 - Produced Water Storage Tanks) APEN - Revision 7/2018 AVIS COLORADO 2 I klaNier Permit Number: TBD AIRS ID Number: 123 [Leave blank unless APCD has already assigned a permit r and AIRS ID] Section 4 - Storage Tank(s) Information Produced Water Throughput: Actual Annual Amount (bbl/year) 124,100 Requested Annual Permit Limits (bbl /year) 148,920 From what year is the actual annual amount? Tank design: ✓❑ Fixed roof O Internal floating roof O External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) PWT-01 (1) 500 -bbl 500 4/2018 5/2018 Wells Serviced by this Storage Tank or Tank Battery (EaP Sites On y) API Number Name of Well Newly Reported Well 05 -123 -46001 Mustang V41-34-33XRLNB ig s Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The MP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.271558/-104.416372 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) EC D-01 35 Indicate the direction of the stack outlet: (check one) Q Upward [] Horizontal O Downward ❑Other (describe): O Upward with obstructing raincap Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter (inches): 96 ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Form APCD-207 Produced Water Storage Tank(s) APEN - Revision 7/2018 COLORADO 3 1 i° > m Permit Number: .l BD MRS ID Number: 123 / I [Leave blank unless APCD has already assigned a permit It and AIRS ID] Section 6 - Control Device Information D Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): % ❑ Combustion Device: Pollutants Controlled: VOC, HAP Rating: 0.91 Type: Enclosed Combustor MMBtu/hr Make/Model: Crimson CE 1000 Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: Minimum Temperature: NIA 1,496 N/A Btu/scf MMBtu/hr 0 Closed Loop System _ Description of the closed loop system: 0 Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 75 psig Describe the separation process between the well and the storage tanks: The well produces to a single stage 3 -phase separator where produced water is separated out and routed to the produced water tank. Form APCD-207 Produced Water Storage Tank{s) APEN - Revision 7/2018 COLORADO 4 V== Permit Number: TBD AIRS 10 Number: 123 [Leave blank unless APCD has already assigned a permit and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the fficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECD 95 NOx CO HAPs ECo 95 Other: From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) Uncontrolled ` Emissions (tons/year) - Controlled Emissions (tons/year) VOC 0.2620 lb/bbl State EF 16.26 0.81 19.51 0.98 NOx 0.0037 lb/bbl State EF N/A 0.23 N/A 0.27 CO 0.0167 lb/bbl State EF N/A 1.04 N/A 1.24 Non -Criteria Reportable Pollutant Emissions Inventory - Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP 42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions s (pounds/year) Benzene 71432 0.0070 lb/bbl State EF 870 44 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0220 lb/bbl State EF 2,732 138 2,2,4-540841 Trimethylpentane 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 Produced Water Storage Tank(s) APEN - Revision 7!2018 5 1 LSi® COLORADO Permit Number: TBD AIRS In Wumber: 192. / / [Leave blank unless ARCO has already assigned a pemit and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. 26.161 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: O Draft permit prior to issuance Ei Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-207 Produced Water Storage Tank(s) APEN - Revision 7/2013 6 I ACOLORADO V WV ' ` E -,..; , Natural Gas ting A °. N - Form i 211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.00v/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: TBD' tgvv.viciv Company equipment Identification: AIRS ID Number: 123 /'fF 1 / OO4 R WVED APCD Stationary Sources Section 1 - Administrative Information Company Name': Bonanza Creek Energy Operating Company, LLC Site Name: Mustang 42-34 Production Facility (COGCC# 453242) Site Location: SENE S34 T4N R63W Mailing Address: (Include Zip Code) 410 17th Street, Suite 1400 Denver, CO 80202 E -Mail Address': Asoehner@bonanzacrk.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Alisson Soehner Phone Number: (303) 803-1752 'Please use the full, legal company'name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. 1 386612 COLORADO Permit Number: TBD AIRS ID Number: 123 / Section 2- Requested Action ✓❑ NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) OR APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: Initial E&P wellsite application. No Pipeline Infrastructure available at this time; produced gas is flared at the Crimson ECD. 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Produced gas venting will be controlled at an ECD For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: / 5 / 19 / 2018 ❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: 24 hours/day 7 Will this equipment be operated in any NAAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions v= I' a 1t t ti.I days/week 52 ❑✓ Yes ❑ Yes weeks/year ❑ No ❑✓ No COLORADO Permit Number: TBD AIRS ID Number: 123 / / 11 Section 4 - Process Equipment Information E Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: # of Pistons: Volume per event: Capacity: Gal/min Leak Rate: Scf/hr/pist MMscf/event if you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Natural Gas Venting Process Parameters4: 1\ tr Liquid Throughput cDt Process Parameters4: ❑✓ Yes ❑ No Maximum Vent Rate: 12 500 7 SCF/hr Vent Gas Heating Value: 1 590 , BTU/SCF Requested: 1/1/0 f ols MMSCF/year Actual: N/A MMSCF/year -OR- Requested: Bbl/yr Actual: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: VOC (mole %) 22.8121 VOC (Weight %) 45.6323 Benzene (mole %) 0.0623 Benzene (Weight %) 0.1747 ✓ Toluene (mole %) 0.0652 Toluene (Weight %) 0.2157 1 Ethylbenzene (mole %) 0.0099 Ethylbenzene (Weight %) 0.0376 i Xylene (mote %) 0.0323 Xylene (Weight %) 0.1299 1 n -Hexane (mole %) 0.4081 n -Hexane (Weight %) 1.2620 ,! 2,2,4-Trimethylpentane (mole %) 0.0002 2,2,4-Trimethylpentane (Weight %) 0.0009 Additional Required Information: • Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) I-r;r P,;_D-2.11 Na =Ni , 03, 201. 7 3I COLORADO H'' Permit Number: TBD AIRS ID Number: 123 / / Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.271558/-104.416372 Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. (.F) Flow Rate (ACFM) Velocity (ft/sec) ECD-01 35 indicate the direction of the stack outlet: (check one) D Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap 96 Section ,6 - Control Device Information ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency % VRU Downtime or Bypassed ❑ Combustion Device: Pollutants Controlled: VOC, HAP Rating: 20 MMBtu/hr Type: Enclosed Combustor Make/Model: Crimson CE 1000 Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: N/A 98 % 98 % Waste Gas Heat Content Constant Pilot Light: E Yes ❑ No Pilot burner Rating 1,590 Btu/scf N/A MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0/0 4I A COLORADO Permit Number: TBD AIRS ID Number: 123 / / Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑ Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SO,, NO,, VOC ECD 98 CO HAPs ECD 98 Other: From what year is the following reported actual annual emissions data? Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Pollutant Uncontrolled Emission Factor Emission Factor Units Emission Factor Source (AP -42, Mfg. etc) Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled (Tons/year) Controlled° (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM 50,E 0.00005 lb/MMBtu AP -42 N/A N/A N/A 0.01 NOX 0.068 lb/MMBtu AP -42 N/A N/A N/A 5.93 VOC 33,556 Ib/MMscf Mass Balance N/A N/A 1,837 36.75 CO 0.310 Ib/MMBtu AP -42 N/A N/A N/A 27.00 Benzene 128.5 Ib/MMscf Mass Balance N/A N/A 7.034 0.141 Toluene 158.6 Ib/MMscf Mass Balance N/A N/A 8.685 0.174 Ethylbenzene 27.6 Ib/MMscf Mass Balance N/A N/A 1.514 0.031 Xylenes 90.4 lb/MMscf Mass Balance N/A N/A 4.949 0.099 n -Hexane 928.0 Ib/MMscf Mass Balance N/A N/A 50.810 1.017 2,2,4-0.7 Trimethylpentane Ib/MMscf Mass Balance N/A N/A 0.037 0.001 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. 7 COLORADO 5IV N•s.i _ Permit Number: TBD AIRS ID Number: 123 / / Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. /1(008 Signature of Legally Authorized P- rn (not a vendor or consultant) Date Alisson Soehner Environmental Engineer, Air Quality Name (please print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 ,. .t' I ._'s PEN For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd calokaDo 6Akio u �' -_ 1/30/2019 State.co.us Executive Branch Mail -APEN Review: Mustang 42-34 Production Facility AIRS ID 123/9FE9 Heat content of waste gas = 1496 Btu/scf (PS Memo 09-02) Volume of waste gas emitted per BBL of liquids produced = 36 scf bbl (PS Memo 09-02) Actual Throughput per year = 124100 bbl Requested Throughput per year = 148920 bbl Actual heat content of waste gas routed to combustion device = 6684 MMBTU per year Requested heat content of waste gas routed to combustion device = 8020 MMBTU per year Criteria Pollutant Emissions Inventory Pollutant - Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units source (AP -42, Mfg., etc.) ) Uncontrolled Emissions (tons/year) Controlled Emissions$ (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC NOx 0.0680 lb/MMBTU AP -42 0.2 0,3 CO 0.3100 lb/MMBTU AP -42 1.0 1.2 Venting • I may have missed it, but is there a gas meter already installed at the facility? • I think all the emissions are based on 109.5 MMscf/year? If so, I would like to redline Section 4 of the APEN and use 109.5 MMSCF/year as the requested throughput. I would appreciate it if you could reply by COB January 31st, Thanks! James Ricci Permit Engineer CDPHE Z1 COLORADO Air Pollution Control Division Department of Public Health E Environment P 303.691.4089 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246 james.ricci@state.co.us I www.colorado.gov/cdphe/apcd Alisson Soehner <ASoehner@bonanzacrk.com> To: "Ricci - CDPHE, James" <james.ricci@state.co.us> Cc: Patrick Dilsaver <pdilsaver@slrconsulting.com> James — Thanks for the email. We will take a look and get back to you. Alisson From: Ricci - CDPHE, James [mailto:james.ricci@state.co.us] Sent: Thursday, January 24, 2019 1:20 PM To: Alisson Soehner <ASoehner@bonanzacrk.com> Subject: [EXTERNAL] APEN Review: Mustang 42-34 Production Facility AIRS ID 123/9FE9 External Sender: Use caution with links/attachments [Quoted text hidden] Thu, Jan 24, 2019 at 1:29 PM Patrick Dilsaver <pdilsaver@sIrconsulting.com> Thu, Jan 24, 2019 at 4:36 PM To: Alisson Soehner <ASoehner@bonanzacrk.com>, "Ricci - CDPHE, James" <james.ricci@state.co.us> James, https b—RiLgoogle.com/mail/u/0?ik=5517734b80&view=pt&search=all&permthid=thread-a%3Ar-8971545259178200942&simpl=msg-a%3Ar-8767105... 2/10 1/30/2019 State.co.us Executive Branch Mail - APEN Review: Mustang 42-34 Production Facility AIRS ID 123/9FE9 Please see below in red for answers. I think the best choice would be to rerun ProMax with some of the discrepancies you found. Let me know and I can work on this and provide necessary redlines. Thanks, Pat SLR ' Patrick Dilsaver Project Scientist t3 307-214-9584 d 970-494-0805 O pdilsaver@slrconsulting.com SLR International Corporation 1612 Specht Point Road, Suite 119, Fort Collins, CO, 80525 rfim. Vt7NRIER5:lntemationaI8usiness ExrdienceAtwrd,2016 Confidentiality Notice and Disclaimer This communication and any attachment(s) contain information which is confidential and may also be legally privileged. It is intended for the exclusive use of the recipient(s) to whom it is addressed. If you have received this communication in error, please e-mail us by return e-mail and then delete the e-mail from your system together with any copies of it. Any views or opinions are solely those of the author and do not represent those of SLR Management Ltd, or any of its subsidiaries, unless specifically stated. From: Alisson Soehner [mailto:ASoehner@bonanzacrk.com] Sent: January 24, 2019 1:29 PM To: Ricci - CDPHE, James Cc: Patrick Dilsaver Subject: RE: [EXTERNAL] APEN Review: Mustang 42-34 Production Facility AIRS ID 123/9FE9 James — Thanks for the email. We will take a look and get back to you. Alisson https://mai l.google.com/mail/u/0? ik=5517734b80&view=pt&search=all&permthid=thread-a %3Ar-8971545259178200942&s im pl=msg-a%a 3Ar-8767105... 3/10 1/30/2019 State.co.us Executive Branch Mail - APEN Review: Mustang 42-34 Production Facility AIRS ID 123/9FE9 From: Ricci - CDPHE, James [mailto:james.ricci@state.co.us] Sent: Thursday, January 24, 2019 1:20 PM To: Alisson Soehner <ASoehner@bonanzacrk.com> Subject: [EXTERNAL] APEN Review: Mustang 42-34 Production Facility AIRS ID 123/9FE9 External Sender: Use caution with links/attachments Hi Alisson, I am reviewing the APENs for the Mustang 42-34 Production Facility AIRS ID 123/9FE9. I have a couple items I was hoping to clarify: General I noticed the sampling was performed at a different facility. Do you have sampling for this facility yet? If not, we are going to request that results of site -specific sampling and analysis be submitted to the Division as part of the self -certification and used to demonstrate compliance with the emissions factors chosen for these emissions point. This initial compliance requirement will be built into the permit. We used a sample from a nearby facility as representative of this site. We understand that site -specific sampling and analysis will be a permit condition and required upon self -certification. Condensate appears to be entered in ProMax at 79 psia. The liquid looks like it was sampled at 79 psig. This appears to have been a typo. If you wish we can rerun ProMax and submit new calcs and redlines to address this and other questions below. Do you know where the Gas inputs to ProMax originated from? (116 deg F and 91.12 psia) The sample was from the Mustang U-22 sales gas analysis included with the submittal. It appears the temperature and pressurewere put in from the condensate sample. Additionally, O2/Argon was not input and ProMax normalized the composition. We can correct this with a new ProMax run if you wish. Condensate Tanks Is condensate throughput going to be measured at the "Flashed Oil" stream seen on the ProMax diagram? If so, I am calculating throughput a bit differently than the 14.9478 gpm listed on the ProMax output. The condensate throughput for this app was input from the "Oil to Tanks" stream. The oil will be measured from truck loadout, and I agree that we should use the "Flash Oil" throughput. We can provide a redline and new calcs with this information. I would propose we will run a new ProMax model with the original intended throughput. bbl 1 year 1 day 1 hr gal gal (Requested)194;910year x 365 day x 24 hr x 60 mini x 42 bbl = 15,575 men • On the ProMax cover page, I saw C3+ Mass Flow "Oil Tank Flash Gas to Flare" = 614.787 ton/year. Where is this number being pulled from? Calculating it manually using the "Oil Tank Flash Gas to Flare" stream, I came up with the following. I must be including something ProMax isn't? ? I believe ProMax is also subtracting the water flow rate (0.990789 lb/hr), this should result in agreement in the numbers. Total Flow (lb/hr) +166.498 Carbon Dioxide (lb/hr) -1.75203 Nitrogen (lb/hr) -0.0736971 Methane (lb/hr) -7.54584 Ethane (lb/hr) -15.8636 C3+ SUM 141.2628 lb/hr C3+ SUM 618.7312 ton/year tps://mail.google.com/mai I/u/0? ik=5517734b80&view=pt&search=al I&permth id=th read-a%3Ar-8971545259178200942&si mp I=msg-a%3Ar-8767105... 4/10 1/30/2019 State.co.us Executive Branch Mail - APEN Review: Mustang 42-34 Production Facility AIRS ID 123/9FE9 • Can you please send me the screen shot of how C30+ was defined in ProMax? Were assumptions made regarding C30+ MW and other properties? We used the Single Oil property in ProMax with a MW of 668.07 and Specific Gravity of 1.0741. I am unsure of where the MW came from, as I am picking this up from someone else who worked on it. I would propose that we just assume all components above C30 are C30, and model as such. This is a conservative assumption as C30 is a lighter hydrocarbon. I can include this change for an updated ProMax run. Let me know your thoughts. • Can you please also send me the W&B Stencil inputs? Screenshot is attached. Produced Water Tanks • I don't believe the interoffice memo for NOx and CO estimations is accepted anymore. I would like to redline the APEN as follows unless you would like to calculate emissions a different way. We agree with this and will update our calculations accordingly. Heat content of waste gas = I 1496 Btu/scf (PS Memo 09.02) Volume of waste gas emitted per BBL of liquids produced = 36 f bbl (PS Memo 09-021 Actual Throughput per year= 124100 bbl Requested Throughput per year = - J 148920 bbl Actual heat content of waste gas routed to combustion device = 6684 MMBTU per year Requested heat content of waste gas routed to combustion device a 8020 MMBTU per year Criteria Pollutant Emissions Inventory Pollutant E nfssion Factor' Actual Annual Emissions miAnnual Permit Requested Emission Limtitsis Uncontrolled Basis Units Source - (AP -12. Mfg., etc.) ' Uncontrodied Controlled Emissions Emisslonsa Iconslyeorl j (total year) Uncontrolled Emissions (rorrs/yfer) Controlled Emissions (conslyeori VOC J I k NOx 0.USB0 Illad1MBTU AP -42 0.2 0.3 co 0.3100 litoMhiBTu) AP -42 f 1.0 1.2 Venting • I may have missed it, but is there a gas meter already installed at the facility? There is an ECD flow meter, I am checking on the exact location. • I think all the emissions are based on 109.5 MMscf/year? If so, I would like to redline Section 4 of the APEN and use 109.5 MMSCF/year as the requested throughput. That is correct, we agree with that redline. I would appreciate it if you could reply by COB January 31st, Thanks! James Ricci Permit Engineer DPHE COLORADO Air Pollution Control Division Department of Pubic Health 6 Environment P 303.691.4089 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246 james.ricci@state.co.us j www.colorado.gov/cdphe/apcd CAMBX 1 S Patrick Dilsaver <pdilsaver@sirconsulting.com> Thu, Jan 24, 2019 at 4:37 PM To: Alisson Soehner <ASoehner@bonanzacrk.com>, "Ricci - CDPHE, James" <james.ricci@state.co.us> https://mai I.google.com/mail/u/0? i k=5517734680&vi ew=pt&search=a I I&pe rmthid=thread-a %3Ar-8971545259178200942&si m p l=msg-a%3Ar-8767105... 5/10 1/30/2019 State.co.us Executive Branch Mail - APEN Review: Mustang 42-34 Production Facility AIRS ID 123/9FE9 W&B attached this time. Patrick Dilsaver Project Scientist ii 307-214-9584 O 970-494-0805 O pdilsaver@slrconsulting.com SLR International Corporation 1612 Specht Point Road, Suite 119, Fort Collins, CO, 80525 Ell El WINNERS; International Business Excefdence Award, 2016 Confidentiality Notice and Disclaimer This communication and any attachment(s) contain information which is confidential and may also be legally privileged. It is intended for the exclusive use of the recipient(s) to whom it is addressed. If you have received this communication in error, please e-mail us,by return e-mail and then delete the e-mail from your system together with any copies of it. Any views or opinions are solely those of the author and do not represent those of SLR Management Ltd, or any of its subsidiaries, unless specifically stated. From: Patrick Dilsaver Sent: January 24, 2019 4:36 PM To: 'Alisson Soehner'; Ricci - CDPHE, James Subject: RE: [EXTERNAL] APEN Review: Mustang 42-34 Production Facility AIRS ID 123/9FE9 James, Please see below in red for answers. I think the best choice would be to rerun ProMax with some of the discrepancies you found. Let me know and I can work on this and provide necessary redlines. Thanks, Pat From: Alisson Soehner [mailto:ASoehner@bonanzacrk.com] Sent: January 24, 2019 1:29 PM To: Ricci - CDPHE, James Cc: Patrick Dilsaver Subject: RE: [EXTERNAL] APEN Review: Mustang 42-34 Production Facility AIRS ID 123/9FE9 James — https://mai I.goog le. com/ma i I/u/0? ik=5517734b80&view=pt&sea rch=a II&permth id=th read -a %3Ar-8971545259178200942&sim pl=msg-a%3Ar-8767105... 6/10 Hello