HomeMy WebLinkAbout20160635.tiff CDPHE I COLORADO
Co
I Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150O St
PO Box 758 RECEIVED
Greeley, CO 80632
FEB 1 6 2016
February 11, 2016
WELD COUNTY
COMMISSIONERS
Dear Sir or Madam:
On February 17, 2016, the Air Pollution Control Division will begin a 30-day public notice period for
Bonanza Creek Energy Operating Company LLC - State Seventy Holes 21-6 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 Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
1
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4lii019-- CA/62,LAJ
,,/ 2016-0635
-d2"b2 0 I le 0-e = Pl-,�(O i 117 ..
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe c .
John W. Hickenlooper, Governor Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer
A CDPHE Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Bonanza Creek Energy Operating Company LLC - State Seventy Holes 21-6 Production Facility
- Weld County
Notice Period Begins: February 17, 2016
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: State Seventy Holes 21-6 Production Facility
Oil and natural gas exploration Et production facility.
Lot 2 of Section 6 of T4N R62W
Weld County
The proposed project or activity is as follows: The applicant proposes to construct and operate a wellhead
production facility which produces both oil and natural gas. First production at the facility began in
November 2014.
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 15WE0363 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Any such comment must be submitted in writing to the following addressee:
Andy Gruel
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
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DRAFT
CDPHE Construction Permit
CO
Air Pollution Control Division
Permit number: 15WE0363 Issuance: 1
Date issued:
Issued to: Bonanza Creek Energy Operating Company LLC
Facility Name: State Seventy Holes 21-6 Production Facility
Plant AIRS ID: 123-9D32
Physical Location: Lot 2 of Section 6 of T4N R62W
County: Weld County
General Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment Equipment Description DescriptionI[) Paint
One (1) Sandpiper G1 F pneumatic water transfer
P-01 005 pump (serial number 2004239), rated at 600 Enclosed flare
scf/hr.
FL-02 006 Venting of sales gas from high pressure separator; Open flare
open flare combusts gas when sales line is down.
Vapor recovery tower (make: Heath Technologies,
VRT-01 008 model: 48"); vapors are typically collected by Enclosed flare
VRU; emissions are controlled by enclosed flare
when VRU is down.
Five (5) low-pressure separators; vapors are
SEP-01 to
SEP-05 009 typically collected by VRU; emissions are Enclosed flare
controlled by enclosed flare when VRU is down.
Vapor balance, and
L-01 010 Condensate loadout to tank trucks. enclosed flare
(
PWT-01 011 Two (2) produced water storage vessels (500 bbl Enclosed flare
each), total 1,000-bbl.
CNDTK-01 012 Ten (10)condensate storage vessels (500-bbl Enclosed flare
each), total 5,000-bbl.
Point 005: This pump may be replaced with another pump in accordance with the provisions of the
Alternate Operating Scenario (AOS) section of permit.
AIRS: 123-9D32 Page 1 of 15
wAims
This II i r e sub all ru and regulations of the Colorado Air Quality Control
Co on a e ad utio vention 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. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operator's responsibility to self-certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self-certify
compliance as required by this permit may be obtained online at
vwvw.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation No. 3, Part B,
Section III.G.2.)
2. 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 No. 3, Part B, Section III.E.)
3. 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
4. Emissions of air pollutants shall not exceed the following limitations. (Regulation No. 3, Part B,
Section I I.A.4.)
Annual Limits:
Facility! AIRS" Tons Per Year Emission
Equipment ID Point SOX VOC CO Type
P-01 005 --- 2.6 1.4 Point
FL-02 006 --- 4.9 2.6 Point
VRT-01 008 --- 11.1 1.9 Point
SEP-01 to SEP-05 009 3.6 7.8 1.9 Point
L-01 . 010 --- 13.0 --- Point
PWT-01 011 --- 2.0 --- Point
CNDTK-01 012 --- 3.8 --- Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility-wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility-wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility-wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
,� GDS ICOLORADO
CO )Air Pollution Control Division
Depahme^s nr wiz I ieatth b`nvirunm-cn. Page 2 of 15
Lon
• •li c 't th nn l limit for both criteria and hazardous air pollutants, shall be
•eter d ro lve ( onth 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.
5. 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 No. 3, Part B, Section III.E.)
Facility AIRS Contrdl Device Pollutants
Equipment ID Point Controlled
P-01 005 Enclosed flare VOC
FL-02 006 Open flare (emergency) VOC
VRT-01 008 Enclosed flare VOC
SEP-01 to SEP-05 009 Enclosed flare VOC
L-01 010 Vapor balance and enclosed flare VOC
PWT-01 011 Enclosed flare VOC
CNDTK-01 012 Enclosed flare VOC
PROCESS LIMITATIONS AND RECORDS
6. 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
P-01 005 Gas vented 5.3 MMscf
FL-02 006 Gas vented to emergency 10.0 MMscf
flare
VRT-01 008 Gas vented from vapor 3.0 MMscf
recovery tower
SEP-01 to SEP-05 009 Gas vented from separators 4.9 MMscf
L-01 010 Liquids loaded 306,600 bbl
PWT-01 011 Produced water throughput 302,220 bbl
CNDTK-01 012 Condensate throughput 306,600 bbl
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
....... _..
c,F1 Aix Pct111 COLORADOn Control Division
CO 1 Deganrtr000t of Dal,-I4eatt,k&ariircmresent Page 3 of 15
a
p). .
o t ve on s' ta. Th ermit holder shall calculate throughput each month and
eep e r site a local field office with site responsibility, for Division
review.
7. Point 009: The owner or operator shall continuously monitor and record the volumetric flow
rate of natural gas vented from the separators using a flow meter. The flow meter shall
continuously measure flow rate and record total volumetric flow vented from each separator.
The owner or operator shall use monthly throughput records to demonstrate compliance with
the process limits specified in Condition 6 and to calculate emissions as described in this
permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
8. The permit number and ten-digit AIRS ID number assigned by the Division (i.e., 123-9D32-xxx)
shall be marked on the subject equipment for ease of identification. (Reference: Regulation
No. 3, Part B, III.E.) (State only enforceable)
9. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of
these sources. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30%opacity for more than six minutes in any sixty
consecutive minutes. Emission control devices subject to Regulation No. 7, Sections XII.C.1.d
or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. l't 4.)
10. These sources are subject to the odor requirements of Regulation No. 2. (State only
enforceable)
11. Fugitive component leaks at this well production facility are subject to the Leak Detection and
Repair (LDAR) program requirements including monitoring, repair, re-monitoring,
recordkeeping, and reporting as described in Regulation No. 7, Section XVII.F. In addition, the
operator shall comply with the General Provisions contained in Regulation No. 7, Section
XVII.B.1.
12. Points 005, 008, 009, 010, 011, 012: The enclosed flares covered by this permit are subject
to Regulation No. 7, Section XII.C General Provisions (State only enforceable), and Regulation
No. 7, Section XVII.B General Provisions (State only enforceable). If a combustion device is
used to control emissions of volatile organic compounds to comply with Section XII.D and/or
Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be
designed so that an observer can, by means of visual observation from the outside of the
enclosed combustion device or by other means approved by the Division, determine whether it
is operating properly. The flares 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.
13. Point 006: The open flare at this emissions point has been approved as an alternative
emissions control device under Regulation Number 7, Section XVII.B.2.e. The open flare must
have no visible emissions during normal operations and be designed so that an observer can, by
means of visual observation from the outside of the open flare, or by other convenient means
approved by the Division, determine whether it is operating properly. This open 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;
CQP4E 1COLORADO
Co !Air Pollution Control Division
• iu. of p,bt rare 6 Ent Page 4 of 15
Dll usti d ices in lied before May 1, 2014, must be equipped with an
e l al 1 er by efore May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
14. Points 006, 008, and 009: The separator covered by this permit is subject to Regulation 7,
Section XVII.G. (State Only). On or after August 1, 2014, gas corning 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.
15. Point 010: This source is located in an ozone non-attainment or attainment-maintenance area
and is subject to the Reasonably Available Control Technology (RACT) requirements of
Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by
submerged fill. (Reference: Regulation 3, Part B, III.E)
16. Point 010: The owner or operator shall follow loading procedures that minimize the leakage of
VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2):
• Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other
liquid or vapor loss during loading and unloading.
• All compartment hatches at the facility (including thief hatches) shall be closed and
latched at all times when loading operations are not active, except for periods of
maintenance, gauging, or safety of personnel and equipment.
• The owner or operator shall inspect onsite loading equipment during loading operations
to monitor compliance with above conditions. The inspections shall occur at least
monthly. Each inspection shall be documented in a log available to the Division on
request.
17. Point 010: All hydrocarbon liquid loading operations, regardless of size, shall be designed,
operated and maintained so as to minimize leakage of volatile organic compounds to the
atmosphere to the maximum extent practicable.
18. Point 012: 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)
19. Points 011 and 012: The storage tanks at these emissions points covered by this permit are
subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The
owner or operator shall install and operate air pollution control equipment that achieves an
average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a
design destruction efficiency of at least 98% for hydrocarbons except where the combustion
device has been authorized by permit prior to May 1, 2014. The source shall follow the
inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of
the inspections for a period of two years, made available to the Division upon request. This
control requirement must be met within 90 days of the date that the storage tank commences
operation.
COPHE COLORADO
co Ass Pollution Control Division
Lexanren r tr ttn&;E.uo,r.n: Page 5 of 15
■
20. IP is 1 d 12: he torage nks covered by this permit are subject to the venting and
ora n ssi geme tem ("STEM") requirements of Regulation Number 7,
Section XVII.C.2.
21. Point 012: 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.
OPERATING Et MAINTENANCE REQUIREMENTS
22. Points 006, 008, 009, 010, 011, 012: 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 OEtM plan are subject to Division approval prior to
implementation. (Regulation Number 3, Part B, Section III.G.7.)
23. Point 010: The owner or operator of a loadout at which vapor balancing is used to control
emissions shall:
a. Install and operate the vapor collection and return equipment to collect vapors during
loading of tank compartments of outbound transport trucks and return these vapors to
the stationary source storage tanks.
b. Include devices to prevent the release of vapor from vapor recovery hoses not in use.
c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred
unless the vapor collection equipment is in use.
d. Operate all recovery and disposal equipment at a back pressure less than the pressure
relief valve setting of transport vehicles.
e. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch
covers shall be weighted and properly seated.
f. Inspect pressure relief devices (PRD) annually for proper operation and replace as
necessary. PRDs shall be set to release at a pressure that will ensure flashing, working
and breathing losses are routed to the control device under normal operating
conditions.
g. Document annual inspections of thief hatch seals and PRD with an indication of status,
a description of any problems found, and their resolution.
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
24. Points 005, 006, 008, 009, 011, 012: Within one hundred and eighty (180)days after issuance
of this permit, the owner or operator shall demonstrate compliance with opacity standards
using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or
absence of visible emissions. "Visible Emissions" means observations of smoke for any period or
periods of duration greater than or equal to one minute in any fifteen minute period during
normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16)
Periodic Testing Requirements
25. Point 009: On an annual basis, the operator shall complete a site-specific extended gas
analysis of the natural gas produced from the separators that is routed to the flare, in order to
verify the VOC content (weight fraction) of this emission stream used in the permit application.
Results of testing shall be used to determine the site-specific emission factors using Division-
approved methods.
DPI !COLORADO
Q 1 AirPollutionControlDivision
1 Department zr r&Errivarrnert Page 6 of 15
�. rr
ALT • F O N CE RI
26. Point 005: This pump may be replaced with a like-kind pump in accordance with the
requirements of Regulation 3, Part A, Section IV.A and without applying for a revision to this
permit or obtaining a new construction permit. A like-kind replacement pump shall be the
same make, model and capacity as authorized in this permit.
27. Point 005: The owner or operator shall maintain a log on-site or at a local field office to
contemporaneously record the start and stop dates of any pump replacement, the
manufacturer, model number, serial number and capacity of the replacement pump.
28. Point 005: All pump replacements installed and operated per the alternate operating
scenarios authorized by this permit must comply with all terms and conditions of this
construction permit.
ADDITIONAL REQUIREMENTS
29. 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.
30. 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).
31. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and
Natural Gas Production Facilities major stationary source requirements shall apply to this
stationary source at any such time that this stationary source becomes major solely by virtue of
$ G;E.HE. I COLORADO
CO Mr Pollution Control Division
Departme^a yr Heatt,.v Erwronrrznt Page 7 of 15
t ti in ny er t limit on and shall be subject to all appropriate applicable
I
n b . (Reg n Number 8, Part E, Subpart HH)
GENERAL TERMS AND CONDITIONS
32. 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.
33. 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.
34. 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.
35. 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.
36. 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.
37. 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.
38. 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:
Andy Gruel, P.E.
Permit Engineer
, COLORADO
CO f Mr Pollution Control Division
De„ur, I•4eattn Enworrrent Page 8 of 15
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Bonanza Creek Energy Operating Company
LLC. Facility-wide construction permit for a
synthetic minor facility.
4, PH COLORADO
CO ''3. Air Pollution Control Division
Dela:emelt %biz IlealtA13 E'rwirarszent. Page 9 of 15
•
Dr No ' th this it issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder shall pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s)operate at the permitted limitations.
Uncontrolled Controlled
AIRS Pollutant CAS# Emissions Emissions
Point (lb/yr) (lb/yr)
Benzene 71432 239 12
Toluene 108883 290 15
Ethylbenzene 100414 109 6
005 Xylenes 1130207 203 11
n-Hexane 110543 1746 88
2,2,4 540841 246 13
Trimethylpentane
Benzene 71432 456 23
Toluene 108883 552 28
Ethylbenzene 100414 207 11
006 Xylenes 1130207 387 20
n-Hexane 110543 3322 167
2,2,4- 540841 467 24
Trimethylpentane
Benzene 71432 4590 230
Toluene 108883 4504 226
008 Ethylbenzene 100414 643 33
Xylenes 1130207 1592 80
n-l-lexane 110543 31576 1579
4, GDPHE ICOLORADO
CO ',f I Air Pollution Control Division
w ; DesArivc-5 of z Heat h El Environment Page 10 of 15
,Ar
I-11°1'1P A VT
. AIRS Uncontrolled Controlled
Paint Pollutant CAS# Emissions Emissions
(Ib/yr) (lb/yr)
008 2'2'4 540841 3152 158
Trimethylpentane
009 Benzene 71432 974 49
009 Toluene 108883 1140 57
009 Ethylbenzene 100414 265 14
009 Xylenes 1130207 477 24
009 n-Hexane 110543 6855 343
009 2'2'4 540841 960 48
Trimethylpentane
010 Benzene 71432 163 109
010 Toluene 108883 130 87
010 Ethylbenzene 100414 11 8
010 Xylenes 1130207 29 20
010 n-Hexane 110543 1717 1142
010 2'2'4 540841 132 88
Trimethylpentane
011 Benzene 71432 2116 106
011 n-Hexane 110543 6649 333
012 Benzene 71432 1288 65
012 Toluene 108883 1288 65
012 Ethylbenzene 100414 129 7
012 Xylenes 1130207 515 26
012 n-Hexane 110543 9014 451
012 2'2'4 540841 1031 52
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 005:
Uncontrolled Controlled
Weigh Emission Emission
CAS# Pollutant Factors Factors Source
Fraction.
of Gas ) lb/MMscf lb/MMscf
• vented vented
N0x (lb/MMBtu) --- --- 0.068 AP-42 Ch. 13-5
CO (lb/MMBtu) --- --- 0.37 AP-42 Ch. 13-5
V0C 30.96 19452 972.6 Emission factors
71432 Benzene 0.0725 45.55 2.28 are based on
108883 Toluene 0.0878 55.19 2.76 the
,h E 'COLORADO
CO f 1 Air Pollution Control Division
Dc-,,xrome°tt`f Pubic 1 "b gnvirontremt Page 11 of 15
■T'.11:? A VT
Uncontrolled Controlled
Emission -Emission
CAS# Pollutant Factors Factors Source
Weight
Fraction lb/MMscf lb/MMscf
0 f Gas ) vented vented
100414 Ethylbenzene 0.0330 20.73 1.04 displacement
1330207 Xylenes 0.06t5 38.66 1.933 equation (see
110543 n-Hexane 0.5288 332.21 16.61 below)and the
site-specific gas
540841 2,2,4-Trimethylpentane 0.0744 46.72 2.34 analysis.
The displacement equation can found in "EPA Emission Inventory Improvement Program
Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)."
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
Point 006:
Uncontrolled Controlled
Weight _. Emission Fission
CAS# Pollutant factors Factors Source
Fraction ib/kMMscf lb/lNMscf
of Gas O4 vented vented
NOx (lb/MMBtu) --- --- 0.068 AP-42 Ch. 13-5
CO (lb/MMBtu) --- --- 0.37 AP-42 Ch. 13-5
VOC 30.96 19452 972.6 Emission factors
71432 Benzene 0.0725 45.55 2.28 are based on
108883 Toluene 0.0878 55.19 2.76 displacement
100414 Ethylbenzene 0.0330 20.73 1.04 equation (see
1330207 Xylene 0.0615 38.66 1.933 below) and the
110543 n-Hexane 0.5288 332.21 16.61 site-specific gas
540841 2,2,4-Trimethylpentane 0.0744 46.72 2.34 analysis.
The displacement equation can found in "EPA Emission Inventory Improvement Program
Publication: Volume II, Chapter 10 Displacement Equation (10.4-3)."
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
Point 008:
Uncontrolled Controlled
Weight Emission Emission
CAS# Pollutant Factors Factors Source
Fraction : ihMMscf tb/MMscf
of Gas(96) vented vented
NOx (lb/MMBtu) --- - 0.068 AP-42 Ch. 13-5
CO (lb/MMBtu) --- --- 0.37 AP-42 Ch. 13-5
VOC 94.45 151261 7563.1 Emission factors
71432 Benzene 0.9838 1573.4 78.67 are based on
108883 Toluene 0.9656 1544.2 77.21 displacement
100414 Ethylbenzene 0.1379 220.6 11.03 equation (see
below)and
1330207 Xylene 0.3413 545.8 27.29 ProMax
6.7681 modeling based
110543 n-Hexane 10824.8 541.24 on a site-
2,2,4_ specific gas
540841 0.6757 1080.7 54.035 analysis.
Trimethylpentane
...._____.......___.... _.........__.._..._____....___-
4, '1P s ICOLORADO
CO f 1 Air Pollution Control Division
3 . ,3tP�H thb QO r Page 12 of 15
11
.•l t qu n an fo in "EPA Emission Inventory Improvement Program
-I• catio . of , - Di ement Equation (10.4-3)."
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
Point 009:
Uncontrolled Controlled
Weight CAS Emission
CAS# Pollutant Factors Emission Factors . Source
Fraction of lb/MMlscf: lb/IrMMscf vented
Gas (%) vented
NOx --- --- 0.068 AP-42 Ch. 13-5
CO --- --- 0.37 AP-42 Ch. 13-5
SOx --- --- 0.698 AP-42 Ch. 13-5
VOC 65.925 63981 3199.1 Emission
71432 Benzene 0.2069 200.76 10.04 factors are
108883 Toluene 0.2423 235.12 11.76 based on
100414 Ethylbenzene 0.0563 54.63 2.73 displacement
equation (see
1330207 Xylene 0.1013 98.33 4.92 below)and
ProMax
modeling
110543 n-Hexane 1.4562 1413.22 70.66 based on a
site-specific
540841 2,2,4-Trimethylpentane 0.2040 198.02 9.90 gas analysis.
The displacement equation can found in "EPA Emission Inventory Improvement Program
Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)."
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
Point 010:
Uncontrolled Controlled
Weight Emission Emission
CAS# Pollutant Fraction of Factors Factors Source
Gas t%) lb/I,otf0gallons lb/I,000gallons
loaded loaded
VOC 90.29 6.01 2.02 AP-42 Ch 5.2 Eqn 1
71432 Benzene 0.2104 0.0127 0.00425 AP-42 Ch 5.2 Eqn 1
108883 Toluene 0.1679 0.0101 0.00339 AP-42 Ch 5.2 Eqn 1
100414 Ethylbenzene 0.0145 0.0009 0.000302 AP-42 Ch 5.2 Eqn 1
1330207 Xylene 0.0370 0.0022 0.000737 AP-42 Ch 5.2 Eqn 1
110543 n-Hexane 2.2169 0.1333 0.04466 AP-42 Ch 5.2 Eqn 1
540841 2,2,4-Trimethytpentane 0.1707 0.0103 0.00345 AP-42 Ch 5.2 Eqn 1
Note: The controlled emissions factors for this point are based on an overall control efficiency of 66.5%,
calculated as follows: collection efficiency of vapor balance is 70% (AP-42 Ch 5.2), and that
collected amount is controlled at enclosed flare at 95%. 0.7*0.95=0.665.
The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1
(version 1/95) using the following values:
L = 12.46*C*S*P*M/T
C = 0.9029 (Weight%VOC, from site-specific sample taken 12/8/2014)
S = 1.0 (Submerged loading: dedicated normal service)
P (true vapor pressure) = 5.6 psia
M (vapor molecular weight) =49.98 lb/lb-mol
T (temperature of liquid loaded) = 523.67 °R
A GDPME COLORADO
Ir.co -. Air Pollution Control Division
Deaartu.,i Est PUC.ic riea[Chs Eivroarman Page 13 of 15
un n lie no rit 'a repo ble air pollutant (NCRP) emission factors were calculated
sing p of t CRP as measured from a site-specific sample taken
12/8/2014, multiplied by the total VOC loading loss ("L")calculated above.
Point 011:
Uncontrolled Controlled
CAS# Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbt
VOC 0.262 0.0131 CDPHE Default
71432 Benzene 0.007 0.00035 CDPHE Default
110543 n-Hexane 0.022 0.0011 CDPHE Default
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
Point 012:
Uncontrolled Controlled..
CAS# Pollutant Emission Factors Emission Factors Source
lb/bbl lbfbbl
NOx (lb/MMBtu) --- 0.068 AP-42 Ch. 13-5
CO (lb/MMBtu) --- 0.37 AP-42 Ch. 13-5
VOC 0.4917 0.0246
71432 Benzene 0.00427 0.00021 Emission factors
108883 Toluene 0.00423 0.00021 are modeled using
Promax and based
on site-specific
100414 Ethylbenzene 0.000608 0.00003
1330207 Xylene 0.00151 0.00008 110543 n-Hexane 0.0295 0.00148 liquids analysis
analysis
obtained
540841 2'2'4 0.0033 0.00016 12/8/2014.
Trimethylpentane
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN 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 Status
Requirement
Operating Permit Synthetic Minor Source of: VOC, NOx, HAP (n-hexane)
NANSR Synthetic Minor Source of: VOC, NOx
MACT HH Area Source
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
# COLORADO
co l I Air Pollution Control Division
..• ? De,a,met feallnv Frame Page 14 of 15
' 0 SIt :: 1Lrt 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
°PRE COLORADO
+O+ Air Pollution Control Dr nston
Page 15 of 15
Colorado Air Permitting Project.
Project Details
Review Engineer: Andy Gruel
Package#: 324384
Received Date: 2/5/2015
Review Start Date: 5/28/2015
Section 01-Facility Information
Company Name: Bonanza Creek Energy Operating Company LLC
, County AIRS ID: 123
Plant AIRS ID: 9D32
Facility Name: State Seventy Holes 21-6 Production Facility
Physical Address/Location: Lot 2,Section 6 of T4N R62W
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) ❑Particulate Matter(PM) ❑r Ozone(NOx&VOC)
Section 02-Emissions Units In Permit Application
Emissions Self Cert
AIRs Point# Emissions Source Type Permit# Issuance# Action Engineering Remarks
Control? Required?
005 Pneumatic Pump Yes 15WE0363 1 Yes Permit Initial Issuance
006 Process Flare Yes 15WE0363 1 Yes Permit Initial ssuance
008 Vapor Recovery Tower{VRT} Yes 15WE0363 1 Yes Permit Initial issuance
009 Separator Venting Yes 15WE0363 1 Yes Permit Initial Issuance
010 Hydrocarbon Liquid Loading Yes 15WE0363 1 Yes Permit Issuance
011 Produced Water Storage Tank Yes 15WE0363 1 Yes Permit Initial Issuance
012 Condensate Storage Tank Yes 15WE0363 1 Yes Permit Initial Issuance
Section 03-Description of Project
Facility-wide permit for an exploration&production facility located in the non-attainment area of Weld County. The facility produces both oil and
natural gas from five wells,with first production in November 2014.
Section 04-Public Comment Requirments
Is Public Comment Required? Yes
If yes,why?" Greater than 25 tons per year in Non-Attainment Area
Section 05-Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required?2 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,explain what programs and which pollutants here:
Title V Operating Permits(OP):VOC,HAPs(n-Hexane)
Non-Attainment New Source Review(NANSR):VOC
Is this stationary source a major source? No
If yes,explain what programs and which pollutants here:
DA
CDPHE Construction Permit
CO '! Air Pollution Control Division
Permit number: 15WE0363 Issuance: I
Date issued:
Issued to: Bonanza Creek Energy Operating Company LLC
Facility Name: State Seventy Holes 21-6 Production Facility
Plant AIRS ID: 123-9D32
Physical Location: Lot 2 of Section 6 of T4N R62W
County: Weld County
General Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment Point Equipment Description Description
ID
One (1) Sandpiper G1 F pneumatic water transfer
P-01 005 pump (serial number 2004239), rated at 600 Enclosed flare
scf/hr.
FL 02 006 Venting of sales gas from high pressure separator; Open flare
open flare combusts gas when sales line is down.
Vapor recovery tower (make: Heath Technologies,
VRT-01 008 model: 48"); vapors are typically collected by Enclosed flare
VRU; emissions are controlled by enclosed flare
when VRU is down.
SEP 01 to Five (5) low-pressure separators; vapors are
SEP-05 009 typically collected by VRU; emissions are Enclosed flare
controlled by enclosed flare when VRU is down.
L-01 010 Condensate loadout to tank trucks. Vapor balance, and
enclosed flare
PWT 01 011 Two (2) produced water storage vessels (500-bbl Enclosed flare
each), total 1,000-bbl.
CNDTK-01 012 Ten (10) condensate storage vessels (500-bbl Enclosed flare
each), total 5,000-bbl.
Point 005: This pump may be replaced with another pump in accordance with the provisions of the
Alternate Operating Scenario (AOS) section of permit.
AIRS: 123-9D32 Page 1 of 15
This is ed sub t all ru s and regulations of the Colorado Air Quality Control
Co ion a • e • • ad• •• utio •'-vention 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. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operator's responsibility to self-certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self-certify
compliance as required by this permit may be obtained online at
www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation No. 3, Part B,
Section III.G.2.)
2. 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 No. 3, Part B, Section TILE.)
3. 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
4. Emissions of air pollutants shall not exceed the following limitations. (Regulation No. 3, Part B,
Section II.A.4.)
)
Annual Limits:
Facility AIRS Tons per Year Emission
Equipment ID Point SOX VOC CO Type
P-01 005 --- 2.6 1.4 Point
FL-02 006 --- 4.9 2.6 Point
VRT-01 008 --- 11.1 1.9 Point
SEP-01 to SEP-05 009 3.6 7.8 1.9 Point
L-01 010 --- 13.0 --- Point
PWT-01 011 --- 2.0 --- Point
CNDTK-01 012 --- 3.8 --- Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility-wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility-wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility-wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
41/4 CalE COLORADO
CO y Air Pollution Control Division
.,: Page 2 of 15
• pli c it th nn :1 limit for both criteria and hazardous air pollutants, shall be
•eter d ro ,v-lve ( 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.
5. 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 No. 3, Part B, Section III.E.)
Facility AIRS Pollutants
Control Device
Equipment ID Point Controlled
P-01 005 Enclosed flare VOC
FL-02 006 Open flare (emergency) VOC
VRT-01 008 Enclosed flare VOC
SEP-01 to SEP-05 009 Enclosed flare VOC
L-01 010 Vapor balance and enclosed flare VOC
PWT-01 011 Enclosed flare VOC
CNDTK-01 012 Enclosed flare VOC
PROCESS LIMITATIONS AND RECORDS
6. 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
P-01 005 Gas vented 5.3 MMscf
FL 02 006 Gas vented to emergency 10.0 MMscf
flare
VRT 01 008 Gas vented from vapor 3.0 MMscf
recovery tower
SEP-01 to SEP-05 009 Gas vented from separators 4.9 MMscf
L-01 010 Liquids loaded 306,600 bbl
PWT-01 011 Produced water throughput 302,220 bbl
CNDTK-01 012 Condensate throughput 306,600 bbl
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
4 COPE COLORADO
CO % Air Pollution Control Division
Page 3 of 15
io t lve on s' ta. Thei •ermit holder shall calculate throughput each month and
eep m e r site •' `.t a local field office with site responsibility, for Division
review.
7. Point 009: The owner or operator shall continuously monitor and record the volumetric flow
rate of natural gas vented from the separators using a flow meter. The flow meter shall
continuously measure flow rate and record total volumetric flow vented from each separator.
The owner or operator shall use monthly throughput records to demonstrate compliance with
the process limits specified in Condition 6 and to calculate emissions as described in this
permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
8. The permit number and ten-digit AIRS ID number assigned by the Division (i.e., 123-9D32-xx)c)
shall be marked on the subject equipment for ease of identification. (Reference: Regulation
No. 3, Part B, III.E.) (State only enforceable)
9. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of
these sources. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty
consecutive minutes. Emission control devices subject to Regulation No. 7, Sections XII.C.1.d
or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. 8 4.)
10. These sources are subject to the odor requirements of Regulation No. 2. (State only
enforceable)
11. Fugitive component leaks at this well production facility are subject to the Leak Detection and
Repair (LDAR) program requirements including monitoring, repair, re-monitoring,
recordkeeping, and reporting as described in Regulation No. 7, Section XVII.F. In addition, the
operator shall comply with the General Provisions contained in Regulation No. 7, Section
XVII.B.1.
12. Points 005, 008, 009, 010, 011, 012: The enclosed flares covered by this permit are subject
to Regulation No. 7, Section XII.C General Provisions (State only enforceable), and Regulation
No. 7, Section XVII.B General Provisions (State only enforceable). If a combustion device is
used to control emissions of volatile organic compounds to comply with Section XII.D and/or
Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be
designed so that an observer can, by means of visual observation from the outside of the
enclosed combustion device or by other means approved by the Division, determine whether it
is operating properly. The flares 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.
13. Point 006: The open flare at this emissions point has been approved as an alternative
emissions control device under Regulation Number 7, Section XVII.B.2.e. The open flare must
have no visible emissions during normal operations and be designed so that an observer can, by
means of visual observation from the outside of the open flare, or by other convenient means
approved by the Division, determine whether it is operating properly. This open 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;
,^ CaPHE COLORADO
CO ' Air Pollution Control Division
Page 4 of 15
• ll om usti d ices in ':lied before May 1, 2014, must be equipped with an
1III
opera ional au o-igni er by or'.efore May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
14. Points 006, 008, and 009: The separator covered by this permit is subject to Regulation 7,
Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced
during normal operation from any newly constructed, hydraulically fractured, or recompleted
oil and gas well, must either be routed to a gas gathering line or controlled from the date of
first production by air pollution control equipment that achieves an average hydrocarbon
control efficiency of 95%. If a combustion device is used, it must have a design destruction
efficiency of at least 98% for hydrocarbons.
15. Point 010: This source is located in an ozone non-attainment or attainment-maintenance area
and is subject to the Reasonably Available Control Technology (RACT) requirements of
Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by
submerged fill. (Reference: Regulation 3, Part B, III.E)
16. Point 010: The owner or operator shall follow loading procedures that minimize the leakage of
VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2):
• Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other
liquid or vapor loss during loading and unloading.
• All compartment hatches at the facility (including thief hatches) shall be closed and
latched at all times when loading operations are not active, except for periods of
maintenance, gauging, or safety of personnel and equipment.
• The owner or operator shall inspect onsite loading equipment during loading operations
to monitor compliance with above conditions. The inspections shall occur at least
monthly. Each inspection shall be documented in a log available to the Division on
request.
17. Point 010: All hydrocarbon liquid loading operations, regardless of size, shall be designed,
operated and maintained so as to minimize leakage of volatile organic compounds to the
atmosphere to the maximum extent practicable.
18. Point 012: 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)
19. Points 011 and 012: The storage tanks at these emissions points covered by this permit are
subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The
owner or operator shall install and operate air pollution control equipment that achieves an
average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a
design destruction efficiency of at least 98% for hydrocarbons except where the combustion
device has been authorized by permit prior to May 1, 2014. The source shall follow the
inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of
the inspections for a period of two years, made available to the Division upon request. This
control requirement must be met within 90 days of the date that the storage tank commences
operation.
* COVME COLORADO
CO ,, Air Pollution Control Division
Page 5 of 15
20. pie. is 11 d 12: The torage nks covered by this permit are subject to the venting and
ora an ssi geme ystem ("STEM") requirements of Regulation Number 7,
Section XVII.C.2.
21. Point 012: 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.
OPERATING £t MAINTENANCE REQUIREMENTS
22. Points 006, 008, 009, 010, 011, 012: 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.)
23. Point 010: The owner or operator of a loadout at which vapor balancing is used to control
emissions shall:
a. Install and operate the vapor collection and return equipment to collect vapors during
loading of tank compartments of outbound transport trucks and return these vapors to
the stationary source storage tanks.
b. Include devices to prevent the release of vapor from vapor recovery hoses not in use.
c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred
unless the vapor collection equipment is in use.
d. Operate all recovery and disposal equipment at a back pressure less than the pressure
relief valve setting of transport vehicles.
e. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch
covers shall be weighted and properly seated.
f. Inspect pressure relief devices (PRD) annually for proper operation and replace as
necessary. PRDs shall be set to release at a pressure that will ensure flashing, working
and breathing losses are routed to the control device under normal operating
conditions.
g. Document annual inspections of thief hatch seals and PRD with an indication of status,
a description of any problems found, and their resolution.
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
24. Points 005, 006, 008, 009, 011, 012: Within one hundred and eighty (180) days after issuance
of this permit, the owner or operator shall demonstrate compliance with opacity standards
using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or
absence of visible emissions. "Visible Emissions" means observations of smoke for any period or
periods of duration greater than or equal to one minute in any fifteen minute period during
normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16)
Periodic Testing Requirements
25. Point 009: On an annual basis, the operator shall complete a site-specific extended gas
analysis of the natural gas produced from the separators that is routed to the flare, in order to
verify the VOC content (weight fraction) of this emission stream used in the permit application.
Results of testing shall be used to determine the site-specific emission factors using Division-
approved methods.
ca COLORADO
CO If Air Pollution Control Division
pep ,r,„«,f gut, „<<;.,,. Page 6 of 15
ALT; O N CE RI
26. Point 005: This pump may be replaced with a like-kind pump in accordance with the
requirements of Regulation 3, Part A, Section IV.A and without applying for a revision to this
permit or obtaining a new construction permit. A like-kind replacement pump shall be the
same make, model and capacity as authorized in this permit.
27. Point 005: The owner or operator shall maintain a log on-site or at a local field office to
contemporaneously record the start and stop dates of any pump replacement, the
manufacturer, model number, serial number and capacity of the replacement pump.
28. Point 005: All pump replacements installed and operated per the alternate operating
scenarios authorized by this permit must comply with all terms and conditions of this
construction permit.
ADDITIONAL REQUIREMENTS
29. 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 (NOx) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO„ per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
30. 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).
31. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and
Natural Gas Production Facilities major stationary source requirements shall apply to this
stationary source at any such time that this stationary source becomes major solely by virtue of
,, c1gE COLORADO
CO Air Pollution Control Division
f k,ir,>>.;, 1 i orr,,.w r,: Page 7 of 15
la ti in any er t limit. on and shall be subject to all appropriate applicable
requi nt b . (Reg -"'•n Number 8, Part E, Subpart HH)
GENERAL TERMS AND CONDITIONS
32. 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.
33. 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.
34. 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.
35. 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.
36. 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.
37. 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.
38. 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:
Andy Gruel, P.E.
Permit Engineer
COPE COLORADO
CO y Air Pollution Control Division
>_1> , Page 8 of 15
DA
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Bonanza Creek Energy Operating Company
LLC. Facility-wide construction permit for a
synthetic minor facility.
* CDPHE COLORADO
CO , Air Pollution Control Division
Page 9 of 15
No pr ' l th this _;-{' • it issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder shall pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphetaqcc-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 Uncontrolled Controlled
Point Pollutant CAS# Emissions Emissions
(Ib/yr) (lb/yr)
Benzene 71432 239 12
Toluene 108883 290 15
Ethylbenzene 100414 109 6
005 Xylenes 1130207 203 11
n-Hexane 110543 1746 88
2,2,4-
540841 246 13
Trimethylpentane
Benzene 71432 456 23
Toluene 108883 552 28
Ethylbenzene 100414 207 11
006 Xylenes 1130207 387 20
n-Hexane 110543 3322 167
2,2,4-
540841 467 24
Trimethylpentane
Benzene 71432 4590 230
Toluene 108883 4504 226
' 008 Ethylbenzene 100414 643 33
Xylenes 1130207 1592 80
n-Hexane 110543 31576 1579
�1iE COLORADO
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np A
AIRS Uncontrolled Controlled
Point Pollutant CAS# Emissions Emissions
(lb/yr) (lb/yr)
008 2'2'4 540841 3152 158
Trimethylpentane
009 Benzene 71432 974 49
009 Toluene 108883 1140 57
009 Ethylbenzene 100414 265 14
009 Xylenes 1130207 477 24
009 n-Hexane 110543 6855 343
009 2'2'4 540841 960 48
Trimethylpentane
010 Benzene 71432 163 109
010 Toluene 108883 130 87
010 Ethylbenzene 100414 11 8
010 Xylenes 1130207 29 20
010 n-Hexane 110543 1717 1142
010 2'2'4 540841 132 88
Trimethylpentane
011 Benzene 71432 2116 106
011 n-Hexane 110543 6649 333
012 Benzene 71432 1288 65
012 Toluene 108883 1288 65
012 Ethylbenzene 100414 129 7
012 Xylenes 1130207 515 26
012 n-Hexane 110543 9014 451
012 2'2'4 540841 1031 52
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 005:
Uncontrolled Controlled
Weight Emission Emission
CAS# Pollutant Fraction Factors Factors Source
of Gas (%) lb/MMscf lb/MMscf
vented vented
NOx (lb/MMBtu) --- --- 0.068 AP-42 Ch. 13-5
CO (lb/MMBtu) --- --- 0.37 AP-42 Ch. 13-5
VOC 30.96 19452 972.6 Emission factors
71432 Benzene 0.0725 45.55 2.28 are based on
108883 Toluene 0.0878 55.19 2.76 the
4 CLUE COLORADO
CO y Air Pollution Control Division
Page 11 of 15
np A V
Uncontrolled Controlled
Weight Emission Emission
CAS# Pollutant Fraction Factors Factors Source
of Gas (%) lb/MMscf lb/MMscf
vented vented
100414 Ethylbenzene 0.0330 20.73 1.04 displacement
1330207 Xylenes 0.0615 38.66 1.933 equation (see
110543 n-Hexane 0.5288 332.21 16.61 below) and the
site-specific gas
540841 2,2,4-Trimethylpentane 0.0744 46.72 2.34
analysis.
The displacement equation can found in "EPA Emission Inventory Improvement Program
Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)."
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
Point 006:
Uncontrolled Controlled
Weight Emission Emission
CAS# Pollutant Fraction Factors Factors Source
of Gas (%) lb/MMscf lb/MMscf
vented vented
NOx (lb/MMBtu) --- --- 0.068 AP-42 Ch. 13-5
CO (lb/MMBtu) --- --- 0.37 AP-42 Ch. 13-5
VOC 30.96 19452 972.6 Emission factors
71432 Benzene 0.0725 45.55 2.28 are based on
108883 Toluene 0.0878 55.19 2.76 displacement
100414 Ethylbenzene 0.0330 20.73 1.04 equation (see
1330207 Xylene 0.0615 38.66 1.933 below) and the
110543 n-Hexane 0.5288 332.21 16.61 site-specific gas
540841 2,2,4-Trimethylpentane 0.0744 46.72 2.34 analysis.
The displacement equation can found in "EPA Emission Inventory Improvement Program
Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)."
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
Point 008:
Uncontrolled Controlled
Weight Emission Emission
CAS# Pollutant Fraction Factors Factors Source
of Gas (%) lb/MMscf lb/MMscf
vented vented
NOx (lb/MMBtu) --- --- 0.068 AP-42 Ch. 13-5
CO (lb/MMBtu) --- --- 0.37 AP-42 Ch. 13-5
VOC 94.45 151261 7563.1 Emission factors
71432 Benzene 0.9838 1573.4 78.67 are based on
108883 Toluene 0.9656 1544.2 77.21 displacement
100414 Ethylbenzene 0.1379 220.6 11.03 equation (see
0.3413 below) and
1330207 Xylene545.8 27.29 ProMax
110543 n-Hexane 6.7681 10824.8 541.24 modeling based
on a site-
540841 2,2,4 0.6757 1080.7 54.035 specific gas
Trimethylpentane analysis.
4CDPH COLORADO
1/4 CO Air Pollution Control Division
_ :: , .orwai-: c;y:r,€.o:al.orncat Page 12 of 15
D.pl t qu on an fou in "EPA Emission Inventory Improvement Program
-1. lcatio . of , C 0 - Di cement Equation (10.4-3)."
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
Point 009:
Uncontrolled Controlled
Weight Emission
CAS# Pollutant Fraction of Factors Emission Factors Source
Gas (%) lb/MMscf lb/MMscf vented
vented
NOx --- --- 0.068 AP-42 Ch. 13-5
CO --- --- 0.37 AP-42 Ch. 13-5
SOx --- --- 0.698 AP-42 Ch. 13-5
VOC 65.925 63981 3199.1 Emission
71432 Benzene 0.2069 200.76 10.04 factors are
108883 Toluene 0.2423 235.12 11.76 based on
100414 Ethylbenzene 0.0563 54.63 2.73 displacement
equation (see
1330207 Xylene 0.1013 98.33 4.92 below) and
' ProMax
modeling
110543 n-Hexane 1.4562 1413.22 70.66 based on a
site-specific
540841 2,2,4-Trimethylpentane 0.2040 198.02 9.90 gas analysis.
The displacement equation can found in "EPA Emission Inventory Improvement Program
Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)."
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
Point 010:
Uncontrolled Controlled
Weight Emission Emission
CAS# Pollutant Fraction of Factors Factors Source
Gas(%) lb/1,000gallons Ib/1,000gallons
loaded loaded
VOC 90.29 6.01 2.02 AP-42 Ch 5.2 Eqn 1
71432 Benzene 0.2104 0.0127 0.00425 AP-42 Ch 5.2 Eqn 1
108883 Toluene 0.1679 0.0101 0.00339 AP-42 Ch 5.2 Eqn 1
100414 Ethylbenzene 0.0145 0.0009 0.000302 AP-42 Ch 5.2 Eqn 1
1330207 Xylene 0.0370 0.0022 0.000737 AP-42 Ch 5.2 Eqn 1
110543 n-Hexane 2.2169 0.1333 0.04466 AP-42 Ch 5.2 Eqn 1
540841 2,2,4-Trimethylpentane 0.1707 0.0103 0.00345 AP-42 Ch 5.2 Eqn 1
Note: The controlled emissions factors for this point are based on an overall control efficiency of 66.5%,
calculated as follows: collection efficiency of vapor balance is 70% (AP-42 Ch 5.2), and that
collected amount is controlled at enclosed flare at 95%. 0.7*0.95 = 0.665.
The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1
(version 1/95) using the following values:
L = 12.46*C*S*P*M/T
C = 0.9029 (Weight % VOC, from site-specific sample taken 12/8/2014)
S = 1.0 (Submerged loading: dedicated normal service)
P (true vapor pressure) = 5.6 psia
M (vapor molecular weight) = 49.98 lb/lb-mol
T (temperature of liquid loaded) = 523.67 °R
'A` A COLORADO
CO ' Air Pollution Control Division
Page 13 of 15
1
un n lie non rit 'a repor ble air pollutant (NCRP) emission factors were calculated
using p e of th- ,CRP as measured from a site-specific sample taken
12/8/2014, multiplied by the total VOC loading loss ("L") calculated above.
Point 011:
Uncontrolled Controlled
CAS# Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
VOC 0.262 0.0131 CDPHE Default
71432 Benzene 0.007 0.00035 CDPHE Default
110543 n-Hexane 0.022 0.0011 CDPHE Default
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
Point 012:
Uncontrolled Controlled
CAS# Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
NOx (lb/MMBtu) --- 0.068 AP-42 Ch. 13-5
CO (lb/MMBtu) --- 0.37 AP-42 Ch. 13-5
VOC 0.4917 0.0246
71432 Benzene 0.00427 0.00021 Emission factors
108883 Toluene 0.00423 0.00021 are modeled using
Promax and based
100414 Ethylbenzene 0.000608 0.00003
1330207 Xylene 0.00151 0.00008 on site specific
110543 n-Hexane 0.0295 0.00148 liquids analysis
obtained
540841 2,2,4 0.0033 0.00016 12/8/2014.
Trimethylpentane
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN 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 Status
Requirement
Operating Permit Synthetic Minor Source of: VOC, NOx, HAP (n-hexane)
NANSR Synthetic Minor Source of: VOC, NOx
MACT HH Area Source
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
* CDPHE COLORADO
Co L-. Air Pollution Control Division
., -: Page 14 of 15
I)
III A
.0. .! S r ,.rt 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
CO I% Air Pollution Control Division
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