HomeMy WebLinkAbout20183542.tiff CD Pit EICOLORADO
43/
co ✓ Department of Public
Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board RECEIVED
1150 O St 201
PO Box 758 NOV 1
Greeley, CO 80632 WELD COUNTY
October 25, 2018 COMMISSIONERS
Dear Sir or Madam:
On November 1, 2018, the Air Pollution Control Division will begin a 30-day public notice period for
Bonanza Creek Energy Operating Company, LLC - Crow Valley 7-62-32-1H. A copy of this public notice
and the public comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I
John W. Hickenlooper, Governor Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer
Public
``1�(�2viwj Cc. PL(TP., Ht.(ST),PW(ERICH/Jm/cis)
tl / ( / ( g It /5/ I8' 2018-3542
CDPHE Air Pollution Control Division
CO
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Bonanza Creek Energy Operating Company, LLC - Crow Valley 7-62-32-1H - Weld County
Notice Period Begins: November 1, 2018
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: Bonanza Creek Energy Operating Company, LLC
Facility: Crow Valley 7-62-32-1H
Oil and gas production facility
SESE Sec 32 T7N R62W
Weld County
The proposed project or activity is as follows: Source is requesting to increase gas routed to flare from 3
MMscf/yr to 15 MMscf/yr.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 16WE0324 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.cotorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Any such comment must be submitted in writing to the following addressee:
Carissa Money
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
1 AV
CDPI4 O
Ai1rcon4n
�. Dena ent o1ztic Neait Envlrorr' , t
CONSTRUCTION PERMIT
Permit number: 16WE0324 Issuance: 2
Date issued:
Bonanza Creek Energy Operating
Issued to: Company, LLC
Facility Name: Crow Valley 7-62-32-1H Production Facility
Plant AIRS ID: 123/9705
Physical Location: SESE SEC 32 T7N R62W
County: Weld County
General
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment ID Point Equipment Description Description
ECD 01 008 Venting of produced natural gas from one two Enclosed Flare
phase inlet separator and heater treater
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. This construction permit represents final permit approval and authority to operate this emissions
source. Therefore, it is not necessary to self-certify. (Regulation Number 3, Part B, Section
III.G.5.)
EMISSION LIMITATIONS AND RECORDS
2. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part
B, Section II.A.4.)
)
Annual Limits:
Facility AIRS Tons per Year Emission
Equipment ID Point PM2.5 NOX VOC CO Type
ECD-01 008 --- --- 6.2 3.1 Point
DP" COLORADO
Ca '-e. Air Pollution Control Dfvision
Page 1 of 6
901 -NIA,
ya r tOl yue
kte: See No - to Per Holderr'for informatgn d, mission fact}rs ant fnethods use A0 calculate
*its. 14, f
Wb a � �nGN
pliance 4H the& nual Willits, for th trite and ha dous air polluta _ shall be
filiaetillin a rot: lve O21ffigntaptal. By_.aS„ , gd of a hsmonth a ne > month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
3. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility AIRS Pollutants
Control Device
Equipment ID Point Controlled
ECD-01 008 Enclosed Flare VOC and HAP
PROCESS LIMITATIONS AND RECORDS
4. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility AIRS Process Parameter Annual Limit
Equipment ID Point
ECD-01 008 Gas Venting to flare 15.0 MMSCF
Compliance with the annual throughput limits shall be determined on a rolling twelve(12) month
total. By the end of each month a new twelve-month total is calculated based on the previous
twelve months' data. The permit holder shall calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Division review.
5. The owner or operator shall continuously monitor and record the volumetric flow rate of gas
vented from the separator(s) and heater treater to the flare using the flow meter. The owner or
operator shall use monthly throughput records to demonstrate compliance with the process limits
contained in this permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
6. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part
B, Section III.E.) (State only enforceable)
7. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall
allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity
for a period or periods aggregating more than six minutes in any sixty consecutive
minutes. (Regulation Number 1, Section II.A.5.)
8. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
OPERATING £t MAINTENANCE REQUIREMENTS
9. 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.)
cal E COLORADO
O Air Pollution Control Divisson
ir
Page 2 of 6
h
COMPLI' E TESTIN D S LI
10. s source is req d tor:", ply with ' es nd sam ;_ g re irements
ADDITI L R ENTS
11. All previous versions of this permit are cancelled upon issuance of this permit.
12. A revised Air Pollutant Emission Notice (APEN)shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
13. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such
time that this source becomes major solely by virtue of a relaxation in any permit condition. Any
relaxation that increases the potential to emit above the applicable Federal program threshold
will require a full review of the source as though construction had not yet commenced on the
source. The source shall not exceed the Federal program threshold until a permit is granted.
(Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
14. 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.
15. 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
cOPHE COLORADO
O Air Pollution Control Division
Page 3 of 6
tgi
h final aut 4 'zati De '1V for obtainin in thorizati rate are to ed in the
Requirement Self9 r Final Au �� %. section is rmit.
16. 9s permit sued i s Banc uion the,. curacy a omple ss of informatio -t 1pplied by
or operate' isv nditr d uponmcaitdtxt_ activity, ction,
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.
17. 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.
18. 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.
19. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission
Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a
source or activity is to be discontinued, the owner must notify the Division in writing requesting
a cancellation of the permit. Upon notification, annual fee billing will terminate.
20. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Carissa Money
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 July 26, 2016 Issued to Issued to Bonanza Creek Energy Operating
Company, LLC for venting of gas from one
separator to flare
Issuance 2 This issuance Increase requested throughput from 3 MMscf to 15
MMscf/yr and increase requested VOC limit from
1.3 to 6.2 tpy.
cOPtit COLORADO
_ Air Pollution Control Antis=
Page 4 of 6
;- h 3 W z v�3
,17
Notes t• '-rmit Hold t the es permit isstlanc
1) The ►p;rmit holde g requi to ees for t '> time fo is pe nit. An invo for these
fee "ll be issu-• .fter t •ermi issued e permit lder sh ay the invoice w n 30 days
r " e inv•. Wig=ure tit invoi tittestitattorevocation o ermit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice(APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to
the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
Facility AIRS Uncontrolled Controlled
Equipment ID Point Pollutant CAS# Emissions Emissions
(Ib/yr) (lb/yr)
Benzene 71432 382 19
Toluene 108883 193 10
Ethylbenzene 100414 14 1
ECD 01 008 Xylenes 1330207 42 2
n-Hexane 110543 2,871 144
2,2,4-
540841 260 13
Trimethylpentane
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250
pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air
Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 008:
Uncontrolled Controlled
CAS# Pollutant Weight Emission Emission Source
Percent of Factors Factors
Gas (%) (lb/MMSCF) (lb/MMSCF)
N0x --- 89.35 89.35 AP-42, Table 13.5-1
CO --- 407.34 407.34 AP-42, Table 13.5-2
V0C 27.34 16,552.44 827.62 Extended gas
analysis
71432 Benzene 0.042 25.55 1.27 Extended gas
analysis
Extended gas
108883 Toluene 0.021 12.88 0.64 analysis
ego a COLORADO
CO Air Pollution Control Division
Page 5 of 6
ir
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27,
oiled Cif
a=y. JOT
Weight :E issiog
` luta rce
Per,cent of Fact` actors
t 'G$_(910) (lb/MM (lbM MSCF)
100414 Ethylbenzene 0.0014 0.84 4.2x10-2 Extended gas
analysis
1330207 Xylene 0.0046 2.8 0.14 Extended gas
analysis
110543 n-Hexane 0.316 191.46 9.57 Extended gas
analysis
540841 2,2,4- 0.028 17.18 0.85 Extended gas
Trimethylpentane analysis
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the November
03, 2015 analysis of a sales gas sample collected from the Crow Valley 7-62-32-1H well. The
controlled VOC and HAP emissions factors for point 008 are based on the flare control efficiency
of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this
permit is valid for a term of five years from the date it was received by the Division. A revised APEN
shall be submitted no later than 30 days before the five-year term expires. Please refer to the most
recent annual fee invoice to determine the APEN expiration date for each emissions point associated
with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-
3150.
7) This facility is classified as follows:
Applicable Requirement Status
Operating Permit Synthetic Minor Source of:
VOC
NANSR Synthetic Minor Source of:
VOC
8) 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
CDPHE COLORADO
Air Pollution Control Division
Page 6 of 6
Colorado Air Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details
Review Engineer: Carissa Money
Package#: 384699
Received Date: 6/29/2018.
Review Start Date: 10/15/2018
Section 01-Facility Information
Company Name: Bonanza Creek Energy Operating Company,LLC Quadrant Section Township Range
County AIRS ID: 123 SESE 32 .-7N 62 _.
Plant AIRS ID: 9705'
Facility Name: Crow Valley 7-62.32-1H -Physical
Address/Location: SESE quadrant of Section 32,Township 7N,Range 62W
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 3�
If yes,for what pollutant? ❑ Carbon Monoxide L 3(CO) Particulate Matter(PM) E Ozone(NOx e.VOC)
Section 02-Emissions Units In Permit Application
Emissions Self Cert Engineering
AIRS Point 6 Emissions Source Type Equipment Name Permit II Issuance 6 Action
Control? Required? Remarks
Permit
008 Separator Verrong ECO-01 Yes 16WEO324 2 No Modification:
•
Section 03-Description of Project
Source is requesting to increase vented gas throughput from 3 MMscf/yr to 15 MMscf/yr.The source had provided the self-certification and the FA inspector approved it.
Thus,I will issue this permit as final.
Section 04-Public Comment Requirements
Is Public Comment Required? yes
If yes,why? Requesting Synthetic Minor Permit
Section 05-Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD)
Title V Operating Permits(OP) J
Non-Attainment New Source Review(NAN5R) ~ J
Is this stationary source a major source? No. -
If yes,explain what programs and which pollutants hers 502 NOx CO VOC PM2.5 PIVI10 TSP HAPs
Prevention of Significant Deterioration(PSD) ❑ C ❑ ❑
Title V Operating Permits(OP) r---- IL-TL ll"""_""
Colorado Air Permitting Project
Non-Attainment New Source Review(NANSR) — u -
Separator Venting Emissions Inventory
008 Separator Venting
123 9701 008 a
Facility AIRS ID, "-'---
County Plant Point
Section 02-Equipment Description Details
;tenting of low pressure natural gas wises gas compressors are not operational or sales pipeline is unavailable
Detailed Emissions Unit Description: .. '
:Enclosed flare
Emission Control Device Description:
Requested Overall VOC&HAP Control Effidiency%: •� , „ 95 „
Limited Process Parameter •
Gas meter
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Separator
Actual Throughput MMscf per year
Requested Permit Limit Throughput= , ,,,,, 713.0 MMscf per year Requested Monthly Throughput= 1 MMscf per month
Potential to Emit(PTE)Throughput= 15 MMscf per year
Process Control(Recycling)
Equipped with a VRU:t-ij'AirtfaiNri
Is VRU process equipment:
Secondary Emissions-Combustion Device(s)for Air Pollution Control
Separator Gas Heating Value: 13141.:Btu/scf
Volume of waste gas emitted per BBL of f
liquids throughput: ��/��scf/bbl
Section 04-Emissions Factors&Methodologies
Description
Source used mass balance and site specific gas analysis collected 11/3/2015
MW � '2.9461]lb/Ib-mol Displacement Equation
Ex=Q*MW*Xx/C
Weight
Helium 0 0204
CO2 5 7335
N2 rd,08355:
methane 50 3316:
ethane ''1c 1353!
propane 14.6942
isobutane : 1.9559
n-butane 6.0145
isopentane 13213
n-pentane 1.7016
cyclopentane 0.1311
n-Hexane LL0 3161
cyclohexane 0 0799':
Other hexanes - 0.5052:
heptanes 0.3247
methylcyclohexane =a'0 24661
224-TMP 0.0286
Benzene 0 0421
Toluene 0.0212
Ethylbenzene 0.0015
Xylenes -0.0046
C8+Heavies ?''0 0753'
Total 100.00
VOC Wt% 27.34
Emission Factors Separator Venting
Uncontrolled Controlled
Emission Factor Source
Pollutant (lb/MMscf) (lb/MMscf) -
(Gas Throughput) (Gas Throughput)
VOC 16555 827.74 "• U3�;a 'g"'
Benzene 25.489 _ 1.2744 _ x '�
Toluene 12.835 0.6418 C
Ethylbenzene 0.9082 0.0454 -:.� 'r T__✓ -
Xylene 2.7850 0.1393 �7t '� g - 5 3
n-Hexane 191.38 9.5689 ' ys
224 TMP 17.316 0.8658 �Exd'gaanaTyss
Primary Control Device
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source
(Waste Heat
Combusted) (Gas Throughput)
PM10 ';'80075 -? 9.791
PM2.$ -,`'.;.0s5075,f�,,,t,: 9.791 AP 42'F-able'
SOx , .'0.0006.aNN 0.773
NOx 010680c 89.352 AF-hg
CO p,31 1 407.340 €: siriar 4.(f
3 of 6 K:\PA\2016\16WE0324.CP2.xlsm
Separator Venting Emissions Inventory
Section 05-Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month)
PM10 0.07 0.00 0.00 0.07 0.07 12
PM2.5 0.07 0.00 0.00 0.07 0.07 12
SOx 0.01 0.00 0.00 0.01 0.01 1
NOx 0.67 0.00 0.00 0.67 0.7 114
VOC 124.16 0.00 0.00 124.16 6.2 1054
CO 3.05 0.00 0.00 3.05 3.1 519
Potential to Emit Actual Emissions Requested Permit Limits Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (Ibs/year) (Ibs/year) (Ibs/year) (Ibs/year) tpy tpy
Benzene 382 0 0 382 19 0.1912 0.0096
Toluene 193 0 0 193 I0 0.0963 0.0048
Ethylbenzene 14 0 0 14 1 0.0068 0.0003
Xylene 42 0 0 42 2 0.0209 0.0010
n-Hexane 2871 0 0 2871 144 1.4353 0.0718
224 TMP 260 0 0 260 13 0.1299 0.0065
Section 06-Reoulatory Summary Ana is
Regulation 3,Parts A,B Source requires a permit
Regulation 7,Section XVII.B,G Source is not subject to Regulation 7,Section XVII.B.2,G
Regulation 7,Section XVII.B.2.e The control device for this separator is not subject to Regulation 7,Section XVI1.8.2.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 gm sample to estimate emissions?
This sample should represent the gas outlet of the equipment covered under this AIRS ID,and should have been collected within one year of the application received date.However,if
the facility has not been modified(e.g.,no new wells brought on-line),then it may be appropriate to use an older site-specific sample.
If no,the permit will contain an"Initial Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
Are facility-wide permitted emissions of VOC greater than or equal to 90 tons per year? ,
If yes,the permit will contain_
-An"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? Yes
If no,the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational(not
to exceed 180 days).This condition will use the"Volume of waste gas emitted per BBL of liquids throughput"(scf/bbl)value in section 03.
Does the company request a control device efficiency greater than 95%for a flare or combustion device? ';Y"=- s
If yes,the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based
on inlet and outlet concentration sampling
You have indicated above that the monitored process parameter is natural gas vented.The fallowing questions do not require an answer.
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Separator Venting Emissions Inventory
Section 08-Technic l Analysis Notes
Sou¢eic usmgsame sfte5peciricgas soosple as used:for OPa.The'sourceasnt required to updatethe gas sample sothey can stilt use the+2015sample..l:used thesameemissionfactors listed in CP1 to provide consiistencysincethesourcee
9
isn't changing the stream-composition.With theinaeased throughput,thefaulity and point are now synthetic minor se he permit must gn through public comment. ,
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Section 09-Inventory SCC Coding and Emissions Factors
Uncontrolled
Emissions
AIRS Pointy Process# SCC Code Pollutant Factor Control% Units
008 01 3-10-001-60 Flares PM10 9.79 0 lb/MMSCF
PM2.5 9.79 0 lb/MMSCF
SOx 0.77 0 Ib/MMSCF
NOx 89.35 0 lb/MMSCF
VOC 16554.73 95 lb/MMSCF
CO 407.34 0 lb/MMSCF
Benzene 25.49 95 Ib/MMSCF
Toluene 12.84 95 lb/MMSCF
Ethylbenzene 0.91 95 lb/MMSCF
Xylene 2.79 95 Ib/MMSCF
n-Hexane 191.38 95 lb/MMSCF
224 TMP 17.32 95 Ib/MMSCF
5 of 6 K:\PA\2016\16WE0324.CP2.xlsm
Separator Venting Regulatory Analysis Worksheet •
Colorado Re.lotion 3 ParenA and B-APEN and Penult Requirements
Source is in the Non-Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions front any criteria pollutants front this individual source greater than 2 TPY(Regulation 3,Part A,Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions greater than 5 TPY,N0x greater than 10 TPY or CO emissions greater than 10 TPY(Regulation 3,Part s,Section 11.03)7
loot enough information
NON-ATTAINMENT
1. Are uncontrolled emissions front any criteria pollutants from this Individual source greater than 1TPY(Regulation 3,Part A,Section ll.D.1.a)? - Y.GOtgt Source Req
2. Are total facility uncontrolled hOC emissions from the greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than lO TPY(Regulation 3,Part 0,Section li It 2( Yes;;".Source Req
!Source requires a permit
Colorado Regulation 7,Section XVII
1. Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014? _ '; Source Is ni
!Source is not subject to Regulation 7,Section XV II.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? r'kVA The control
!The control device for this separator is not subject to Regulation 7,Section XVII.B.2.e
Section XVII.B2e—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 rail control. The use of non-mandafory language such as Yecommend,""may,^"should,"and"can,"is
intended to describe APCD interpretations and recommendations.Mandatorylenninology 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
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Natural Gas Venting APEN - Form -1PCD-211
Air Pollutant Emission Notice (APEN) and •,
Apoliraiion so_r Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN ;If'
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 L.
incorrectly or is missing information and requires re-submittal.
This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms can be found on the Air Pollution Control Division (APCD) website at:
www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 16WE0324 AIRS ID Number: 1 23 /9705/ 008
Company equipment Identification: ECD-01
Section 1 - Administrative Information
Company Name': Bonanza Creek Energy Operating Company, LLC
Site Name: Crow Valley 7-62-32-1 H (COGCC#422674)
Site Location: Site Location
SE/SE Sec. 32, T7N, R62W County: Weld
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip Code) 410 17th Street, Suite 1400
Denver, CO 80202 Permit Contact: Alisson Soehner
Phone Number: (303) 803-1752
E-Mail Address:: asoehner@bonanzacrk.com
'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.
Permits,exemption letters, and any processing invoices will be issued by APCD via e-mail tothe address provided.
_. _ _ {34697 1 /� COLORADO
Permit Number: 16WE0324 AIRS ID Number: 123 /9705/ 008 ft
Section 2- Requested Action
NEW permit OR newly-reported emission source
❑
-OR-
E 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 Et Notes: Increase requested produced gas flaring volume
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: Enclosed combustion device(ECD)used to combust produced natural gas vented from a
two phase inlet separator and heater treater when gas compressors are not operational or the sales pipeline is unavailable.Each ECD has a minimum control efficiency of 95%.
For existing sources, operation began on: 05 / 07 / 2011
For new or reconstructed sources, the projected
start-up date is: / /
0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day days/week weeks/year
Will this equipment be operated in any NAAQS nonattainment O Yes ❑ No
area
Is this equipment located at a stationary source that is ❑ Yes O No
considered a Major Source of(HAP) Emissions
co on..00
2 I`GT
Permit Number: 16WE0324 AIRS ID Number: 123 /9705/ 008
Section 4 - Process Equipment Information
I�E
❑✓ Gas/Liquid Separator I ;
❑ Well Head Casing '1'a1';
❑ Pneumatic Pump Ali
Make: Model: Serial#: Capacity: Gal/min
❑ Compressor Rod Packing
Make: Model: #of Pistons: Leak Rate: Scf/hr/pist
❑ Blowdown Events
#of Events/year: Volume per event: MMscf/event
❑ Other
Description:
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? ✓❑ Yes ❑ No
Maximum Vent 1 712.3 SCF/hr Vent Gas BTU/SCF
Natural Gas Venting Rate: Heating Value:
Process Parameters4: Requested: 15.0 MMSCF/year Actual: MMSCF/year
-OR-
Liquid Throughput
4 Requested: Bbl/yr Actual: Bbl/yr
Process Parameters4:
4 Requested values will become permit limitations. Requested limit(s)should consider future process growth
Molecular Weight: 22.9 lb/lb-mole
VOC (mole%) 12.19 VOC (Weight%) 27.34
Benzene (mole%) 0.012 Benzene (Weight %) 0.042
Toluene (mole%) 0.005 Toluene (Weight %) 0.021
Process Properties:
Ethylbenzene (mole%) 0.001 Ethylbenzene (Weight%) 0.001
Xylene (mole%) 0.001 Xylene (Weight%) 0.005
n-Hexane (mole%) 0.084 n-Hexane (Weight%) 0.316
2,2,4-Trimethylpentane 2,2,4-Trimethylpentane
(mole%) 0.006 (Weight%) 0.028
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)
�GIGR`CC
Permit Number: 16WE0324 AIRS ID Number: 1 23 /9705/ 008 1T'
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.524221/-104.351647
Discharge Height
Operator Temp. Flow Rate Velocity
Stack ID No. Above Ground Level ( F) (ACFM) (ft/sec)
(Feet)
ECD-01 25 1273
Indicate the direction of the stack outlet: (check one)
✓❑ Upward ❑ Downward ❑ Upward with obstructing raincap
❑ Horizontal ❑ Other (describe):
Indicate the stack opening and size: (check one)
E Circular Interior stack diameter (inches): 48
❑ Other (describe):
Section 6 - Control Device Information
Pollutants Controlled:
Size: Make/Model:
❑ VRU:
Requested Control Efficiency
VRU Downtime or Bypassed
Pollutants Controlled: VOC, HAPs
Rating: 10.0 MMBtu/hr
Type: Enclosed Combustor Make/Model: MRW
❑ Combustion Requested Control Efficiency: 95
Device:
Manufacturer Guaranteed Control Efficiency 98
Minimum Temperature: Waste Gas Heat Content 1314 Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating N/A MMBtu/hr
Pollutants Controlled:
❑ Other: Description:
Control Efficiency
Requested
co Lo P„DO
iifi
II�a
Permit Number: 16W E0324 AIRS ID Number: 123 9705 008 ti,-mIl
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):
Overall Requested Control
Pollutant Control Equipment Description Efficiency
(%reduction in emissions)
PM
sox
N OX
VOC ECD 95
CO
HAPs ECD 95
Other:
From what year is the following reported actual annual emissions data?
Use the following table to report the criteria pollutant emissions from source:
(Use the data reported in Sections 4 and 6 to calculate these emissions.)
Emission Requested Annual Permit
Uncontrolled Emission Factor Actual Annual Emissions Emission Limit(s)5
Pollutant Emission Factor Source
Factor Units (AP-42, Uncontrolled Controlled6 Uncontrolled Controlled
Mfg. etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year)
PM 40.0 pg/LA3 AP-42 N/A N/A N/A 0.20
SOX 0.00043 Ib/MMBtu AP-42 N/A N/A N/A 0.004
NOx 0.068 Ib/MMBtu AP-42 N/A N/A N/A 0.67
VOC 16,548.1 lb/MMscf SSEF N/A N/A 124.10 6.21
CO 0.310 IbMMBtu AP-42 N/A N/A N/A 3.06
Benzene 25.55 Ib/MMscf SSEF N/A N/A 0.192 0.010
Toluene 12.88 lb/MMscf SSEF N/A N/A 0.097 0.005
Ethylbenzene 0.84 lb/MMscf SSEF N/A N/A 0.006 <0.001
Xylenes 2.80 Ib/MMscf SSEF N/A N/A 0.021 0.001
n-Hexane 191.39 Ib/MMscf SSEF N/A N/A 1.435 0.072
2,2,4-
17.18 Ib/MMscf SSEF N/A N/A 0.129 0.006
Trimethylpentane
Other: N/A N/A
s 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.
�.a.�� '‘,:7.,:.°:,-.!'-;',-,77
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II !
Permit Number: 16WE0324 AIRS ID Number: 123 /9705/ 008
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true`
and correct.
Ir,
/4‘/10- thAZVid.
Signature of Legalt Authorized Pers ( a vendor or consultant) Date
r
Alisson Soehner Environmental Engineer, Air Quality
Name (please print) Title
Check the appropriate box to request a copy of the:
0✓ Draft permit prior to issuance
El 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: For more information or assistance call:
Colorado Department of Public Health and
Environment Small Business Assistance Program
Air Pollution Control Division (303) 692-3175 or (303) 692-3148
APCD-SS-B 1
4300 Cherry Creek Drive South Or visit the APCD website at:
Denver, CO 80246-1530
https://www.colorado.gov/cdphe/apcd
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
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