HomeMy WebLinkAbout20150891.tiff Exhibit V
State of Colorado Air Permit Application
See attached State of Colorado Air Permit Application submitted March 4, 2014
BOflR fl Y 41017th Street, Suite 1500
(‘\) Denver, CO 80202
C R EER (720) 4404100 20 305-)804 phone
fax
Hcrnaneacrk.cuin
March 4, 2014
Chris Laplante
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
RE: Bonanza Creek Energy Operating Company, LLC
Pronghorn 24-7 Booster Station
Permit Application Package
Weld County, CO
Dear Mr. Laplante,
Bonanza Creek Energy Operating Company, LLC (BCEOC) is pleased to submit the attached permit
application package for the Pronghorn 24-7 Booster Station. In addition to the complete permit application
package please find a check in the amount of $611 .60 for ADEN Filing Fees for four APENs at $152.90
each. Please Invoice BCEOC for the additional $1 ,376.10 for nine additional APENs. The facility is a new
natural gas compressor station.
We trust the attached updated permit application package will meet your expectations and that you will not
hesitate to call me at (720) 440-6133 or Derek Stahl at (720) 440-6169 if you have any questions or need
additional information. We appreciate your prompt attention to this most important project.
Sincerely,
irittip4Ctet-K
Peg fioun
Environmental Regula ory Manager
Rocky Mountain Operations
Attachments: As stated
cc: File
cakpodwr OilgOV 117276.21 BMW OffICT
41017.4 Sine( Sete 1500 1331 Lamar Sraet,Soilte 1135 5601 main Amon,&Ise 210
Deriver. CO 80302 Howtoft, TX 77010 Badersf dd, CA 93309
Office (720) 004100 Office: (713)317-1250 : (661) 638-2730
AEcom
Attachment A -ADEN Filing Fees
(Please find a check in the amount of $611 ,60 for APEN Filing
Fees -- 4 APENs at $152.90 each. Please Invoice Bonanza Creek
for the additional $1,376.10 for nine additional APENs.)
Form APCD-100 Colorado Department of Public Health and Environment tie.)
Air Pollution Control Division
Oil & Gas Industry &Mr.:doDepanment
(gbh!ir l lealtli
Construction Permit Application Completeness Checklist an n"""'i"
Yer. September 28, 2009
Company Name: Bonanza Creek Energy Operating Company, LLC
Source Name: Pronghorn 24-7 Booster Station
Date: Mich 2014
Yes No
Are you requesting a facility wide permit for multiple emissions points? N �
In order to have a complete application, the following attachments must be provided, unless stated
otherwise. If application is incomplete, it will be returned to sender and filing fees will not be refunded.
Attachment Application Element Applicant APCD
A MEN Filing Fees •
E Air Pollutant Emission Notice(s) (APENs) & ■
Application(s) for Construction Permit(s) - APCD Form Series 200
C Emissions Calculations and Supporting Documentation N ■
D Company Contact Information - Form APCD-101 11 []
E Ambient Air Impact Analysis 14El
11 Check here if source emits only VOC (Attachment E not required)
F Facility Emissions Inventory — Form AP'CD-102 VI •
,U Check here if' single emissions point source (Attachment F not required)
C Process description, flow diagram and plot plan of emissions unit and/or
facility
[jj Check here if single emissions point source (Attachment G not required)
H Operating & Maintenance (O&M) Plan -- APCD Form Series 300 ■
Check here if true minor emissions source or application is for a general
permit (Attachment H not required)
I Regulatory Analysis
Q Check here to request APCD to complete regulatory analysis
(Attachment I not required)
Colorado Oil and Gas Conservation Commission (COGCC) 805 Series Rule
Requirements— Form APCD-105
Check here if source is not subject to COGCC 805 Series requirements
(Attachment I not required)
Send Complete Application to: Colorado Department of Public Health & Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Check box if facility is an existing Title V source: ■ Send an additional application copy
Check box if refined modeling analysis included: ■ Send an additional application copy
Page I of 1 FormAPcn-100-Appeomplctoc&aliet.doc
MCOM
Attachment B -Air Pollutant Emission Notice and
Application for Construction Permit
APCD Form 201 -- Compressor Engine (C-1 )
APCD Form 201 - Compressor Engine (C-2)
APCD Form 201 - Compressor Engine (C-3)
APCD Form 201 - Compressor Engine (C-4)
APCD Form 201 - Generator Engine (G-1 )
APCD Form 201 - Generator Engine (G-2)
APCD Form 201 - Vapor Recovery Compressor Engine (C-5)
APCD Form 201 - Vapor Recovery Compressor Engine (C-6)
APCD Form 203 - Fugitive Equipment Leaks
APCD Form 205 - Condensate Storage Tanks
APCD Form 208 - Truck Loadout Operation
APCD Form 211 - Pneumatic Pumps
APCD Form 211 - Vapor Recovery Tower
Cc) c-'' r 5.-.a r 6 Ta n a •
V 5 t2.. pr- .eJ4Ooo . o
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION t �Li'I�`��
*
TELEPHONE: (303) 692-3150 it * al*
* 1876 *
CONSTRUCTION PERMIT
PERMIT NO : 14WE0521
Issuance 1
DATE ISSUED : November 17, 2014
ISSUED TO: Bonanza Creek Energy Operating Company
LLC
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Natural Gas Compressor Station known as the Pronghorn 24-7 Booster Station , located
in the SESW Section 7 , Township 5N , Range 61W, Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
Four (4) above ground 500 bbl (each) atmospheric condensate
CND TK 001 storage tanks. The vapors are routed to an enclosed flare with a
minimum combustion efficiency of 95%.
TL 002 Truck Condensate Loadout
One (1 ) natural gas driven pneumatic water transfer or heat trace
circulation pump (make, model, and serial number: to be provided)
P-1 003 rated at 600 scf/hr. Natural gas discharged from the pump is
routed to an enclosed flare with a minimum combustion efficiency
of 95%.
Vapor Recovery Tower for recovering flash vapors from
condensate off the gas/liquid separator prior to entering the
VRT 004 condensate storage tanks. VRT vapors are primarily controlled by
a Vapor Recovery Unit (VRU) , which recycles vapors back to the
inlet. When the VRU is down, VRT vapors are routed to an
enclosed flare with a minimum combustion efficiency of 95%.
FUG 005 Fugitive equipment leaks
One (1 ) Caterpillar, Model G3516B LE, Serial Number TBD,
natural gas-fired, naturally aspirated , 4SLB reciprocating internal
C-1 006 combustion engine, site rated at 1295 horsepower at 1400 RPM .
This engine shall be equipped with an oxidation catalyst and
air/fuel ratio controller. This emission unit will be wed for natural
gas compression.
AIRS ID: 123/9C89 Page 1 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
Facility AIRS
Equipment Point Description
ID
One ( 1 ) Caterpillar, Model G3516B LE, Serial Number TBD,
natural gas-fired , naturally aspirated , 4SLB reciprocating internal
C-2 007 combustion engine, site rated at 1295 horsepower at 1400 RPM .
This engine shall be equipped with an oxidation catalyst and
air/fuel ratio controller. This emission unit will be wed for natural
gas compression.
One ( 1 ) Caterpillar, Model G3516B LE, Serial Number TBD,
natural gas-fired , naturally aspirated , 4SLB reciprocating internal
C-3 008 combustion engine, site rated at 1295 horsepower at 1400 RPM .
This engine shall be equipped with an oxidation catalyst and
air/fuel ratio controller. This emission unit will be used for natural
gas compression.
One (1 ) Caterpillar, Model G3516B LE, Serial Number TBD,
natural gas-fired , naturally aspirated , 4SLB reciprocating internal
C-4 009 combustion engine, site rated at 1295 horsepower at 1400 RPM .
This engine shall be equipped with an oxidation catalyst and
air/fuel ratio controller. This emission unit will be wed for natural
gas compression.
One (1 ) To Be Determined, Model To Be Determined, Serial
Number To Be Determined , natural gas-fired, 4SRB reciprocating
internal combustion engine, site rated at less than or equal to 130
C-5 010 horsepower at 1800 RPM . This engine shall be equipped with a
non-selective catalytic reduction (NSCR) system and air/fuel ratio
controller. This emission unit will be used as vapor recovery
compressor.
One ( 1 ) To Be Determined , Model To Be Determined , Serial
Number To Be Determined , natural gas-fired, 4SRB reciprocating
internal combustion engine, site rated at less than or equal to 130
C-6 011 horsepower at 1800 RPM . This engine shall be equipped with a
non-selective catalytic reduction (NSCR) system and air/fuel ratio
controller. This emission unit will be used as vapor recovery
compressor.
One ( 1 ) To Be Determined , Model To Be Determined, Serial
Number To Be Determined , natural gas-fired, 4SRB reciprocating
internal combustion engine, site rated at less than or equal to 250
G-1 012 horsepower at 1800 RPM. This engine shall be equipped with a
non-selective catalytic reduction (NSCR) system and air/fuel ratio
controller. This emission unit is used as electrical generator for
prime power.
AIRS ID: 123/9C89 Page 2 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
Facility AIRS
Equipment Point Description
ID
One (1 ) To Be Determined, Model To Be Determined, Serial
Number To Be Determined, natural gas-fired, 4SRB reciprocating
internal combustion engine, site rated at less than or equal to 250
G-2 013 horsepower at 1800 RPM . This engine shall be equipped with a
non-selective catalytic reduction (NSCR) system and air/fuel ratio
controller. This emission unit is used as electrical generator for
prime power.
Equipment blowdown controlled by an emergency flare. Flare has
FL- 1 014 a minimum combustion efficiency of 95% . The flare is not
enclosed.
Point 003: This pump may be replaced with another pump in accordance with the
provisions of the Alternate Operating Scenario (AOS) in this permit.
Points 006-009: Each of these engines may be replaced with another engine in
accordance with the temporary engine replacement provision or with another Caterpillar
G3516B LE engine in accordance with the permanent replacement provision of the
Alternate Operating Scenario (AOS) , included in this permit as Attachment A.
Points 010-013: Each of these engines may be replaced with another engine in
accordance with the temporary engine replacement provision or with the manufacturer and
model submitted to the Division per Requirements to Self-Certify for Final Authorization in
accordance with the permanent replacement provision of the Alternate Operating Scenario
(AOS), included in this permit as Attachment A.
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 THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1 , YOU MUST notify the Air Pollution Control Division (the Division) no later than
fifteen days after commencement of operation, by submitting a Notice of Startup
form to the Division. The Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms. html. Failure to notify the Division of startup
of the permitted source is a violation of Air Quality Control Commission (AQCC)
Regulation No. 3, Part B, Section III .G . 1 and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) after commencement of operation ,
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. (Reference: Regulation No. 3, Part B, I II .G .2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the date
AIRS ID: 123/9C89 Page 3 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
on which such construction or activity was scheduled to commence as set forth in the
permit application associated with this permit; (ii) discontinues construction for a period
of eighteen months or more; (iii) does not complete construction within a reasonable
time of the estimated completion date. The Division may grant extensions of the
deadline per Regulation No. 3, Part B, III . F.4 .b. (Reference: Regulation No. 3, Part B,
III . F.4.)
4 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.
(Reference: Regulation No. 3, Part B, Section III . E.)
5 Points 006-009: The following information shall be provided to the Division within fifteen
(15) days after commencement of operation .
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III . E.)
6. Points 010-013: The following information shall be provided to the Division within fifteen
(15) days after commencement of operation.
• manufacturer
• model number
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3 , Part B, III . E.)
7 Points 010-013: Within thirty (30) days after commencement of operation of these
engines, the owner/operator shall submit to the Division a complete APEN and
application to modify this permit to reflect the equipment installed under this permit.
8 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
9. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis) . (Reference: Regulation No. 3, Part B, Section II .A.4)
Monthly Limits:
Facility AIRS Pounds per Month
Emission Type
VOC CO
Equipment ID Point NOx
CND TK 001 --- 36 --- Point
TL 002 1189 --- Point
P-1 003 51 493 238 Point
VRT 004 102 3232 527 Point
AIRS ID: 123/9C89 Page 4 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
FUG 005 --- 1835 --- Fugitive
C-1 006 1062 1486 2123 Point
C-2 007 1062 1486 2123 Point
C-3 008 1062 1486 2123 Point
C-4 009 1062 1486 2123 Point
C-5 010 221 153 425 Point
C-6 011 221 153 425 Point
G-1 012 408 289 815 Point
G-2 013 408 289 815 Point
FL-1 014 68 747 360 Point
(Note: Monthly limits are based on a 31-day month.)
Annual Limits :
Facility AIRS Tons per Year
Emission Type
X
Equipment ID Point NO VOC CO
CND TK 001 --- 0.2 --- Point
TL 002 --- 7.0 --- Point
P-1 003 0.3 2.9 1 .4 Point
VRT 004 0.6 19.03 3.1 Point
FUG 005 --- 10.8 --- Fugitive
C-1 006 6.25 8.75 12.5 Point
C-2 007 6.25 8.75 12.5 Point
C-3 008 6.25 8.75 12.5 Point
C-4 009 6.25 8.75 12.5 Point
C-5 010 1 .3 0.9 2.5 Point
C-6 011 1 .3 0.9 2.5 Point
G-1 012 2.4 1 .7 4.8 Point
G-2 013 2.4 1 .7 4.8 Point
FL-1 014 0.4 4.4 2.1 Point
AIRS ID: 123/9C89 Page 5 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
During the first twelve (12) months of operation, compliance with both the monthly and
annual emission limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)
from each emission unit, on a rolling twelve ( 12) month total. By the end of each month
a new twelve-month total shall be calculated based on the previous twelve months' data.
The permit holder shall calculate emissions each month and keep a compliance record
on site or at a local field office with site responsibility, for Division review. This rolling
twelve-month total shall apply to all permitted emission units, requiring an APEN, at this
facility.
10. Point 005: The operator shall calculate actual emissions from this emissions point
based on representative component counts for the facility with the most recent gas
analysis, as required in the Compliance Testing and Sampling section of this permit.
The operator shall maintain records of the results of component counts and sampling
events used to calculate actual emissions and the dates that these counts and events
were completed . These records shall be provided to the Division upon request.
11 . The owner or operator shall track emissions from all insignificant activities at the facility
on an annual basis to demonstrate compliance with the facility emission limitations as
seen below. An inventory of each insignificant activity and associated emission
calculations shall be made available to the Division for inspection upon request. For the
purposes of this condition, insignificant activities shall be defined as any activity or
equipment, which emits any amount but does not require an Air Pollutant Emission
Notice (APEN).
Total emissions from the facility, including permitted emissions and insignificant
activities, shall remain below:
• 10 tons per year of a single hazardous air pollutant and/or
• 25 tons per year of total hazardous air pollutants (HAP).
12. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III .E.)
Facility AIRS
Equipment Point Control Device Pollutants Controlled
ID
CND TK 001 Enclosed Flare VOC & HAPs
P-1 003 Enclosed Flare VOC & HAPs
VRT 004 Enclosed Flare VOC & HAPs
C-1 006 Oxidation Catalyst CO, VOC, & HCHO
C-2 007 Oxidation Catalyst CO, VOC, & HC HO
AIRS ID: 123/9C89 Page 6 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
C-3 008 Oxidation Catalyst CO, VOC, & HC HO
C-4 009 Oxidation Catalyst CO, VOC, & HC HO
C-5 010 NSCR/AFRC NOx & CO
C-6 011 NSCR/AFRC NOx & CO
G-1 012 NSCR/AFRC NOx & CO
G-2 013 NSCR/AFRC NOx & CO
FL-1 014 Flare VOC & HAPs
PROCESS LIMITATIONS AND RECORDS
13. 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. (Reference:
Regulation 3, Part B, II .A.4)
Process/Consumption Limits
Facility AIRS Monthly Limit
Equipment Point Process Parameter Annual Limit (31 days)
ID
CND TK 001 Condensate Throughput 43,800 BBL/yr 3720 BBL/month
TL 002 Condensate Loaded 43,800 BBL/yr 3720 BBL/month
P-1 003 Motive Gas Consumed 5.3 MMscf/yr 0.5 MMscf/month
VRT 004 VRT Gas Vented 91 .3 MMscf/yr 7.8 MMscf/month
FUG 005 NA --- ---
C-1 006 Consumption of natural gas as fuel 65.1 MMscf/yr 5.5 MMscf/month
C-2 007 Consumption of natural gas as fuel 65. 1 MMscf/yr 5.5 MMscf/month
C-3 008 Consumption of natural gas as fuel 65.1 MMscf/yr 5.5 MMscf/month
C-4 009 Consumption of natural gas as fuel 65.1 MMscf/yr 5.5 MMscf/month
C-5 010 Consumption of natural gas as fuel 7.3 MMscf/yr 0.6 MMscf/month
C-6 011 Consumption of natural gas as fuel 7.3 MMscf/yr 0.6 MMscf/month
G-1 012 Consumption of natural gas as fuel 13.3 MMscf/yr 1 . 1 MMscf/month
G-2 013 Consumption of natural gas as fuel 13.3 MMscf/yr 1 . 1 MMscf/month
FL-1 014 Natural gas flaring 10.7 MMscf/yr 0.9 MMscf/month
The owner or operator shall calculate monthly process rates based on the calendar
month.
During the first twelve (12) months of operation, compliance with both the monthly and
annual throughput limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
AIRS ID: 123/9C89 Page 7 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
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.
STATE AND FEDERAL REGULATORY REQUIREMENTS
14 Points 001 -004,006-014: The permit number and AIRS ID point number (e.g.
123/4567/890) shall be marked on the subject equipment for ease of identification.
(Reference: Regulation Number 3, Part B , III . E.) (State only enforceable)
15 . Visible emissions shall not exceed twenty percent (20%) opacity during normal operation
of the source. During periods of startup, process modification , or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in
any sixty consecutive minutes. Emission control devices subject to Regulation 7,
Sections XII .C. 1 .d or XVII . B. 1 .c shall have no visible emissions. (Reference: Regulation
No. 1 , Section II .A. 1 . & 4. )
16. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
17 Points 001 , 003, and 004: No owner or operator of a smokeless flare or other flare for
the combustion of waste gases shall allow cc 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. (Reference: Regulation No. 1 ,
Section II .A. 5 .)
18 . Point 001 : The flare used to control emissions from the condensate storage tanks is
subject to Regulation No. 7 , Section XII .C General Provisions (State only enforceable).
If a combustion device is used to control emissions of volatile organic compounds to
comply with Section XII .D, it shall 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. The operator shall comply with all applicable
requirements of Section XII .
19 . Point 001 : This source is subject to the recordkeeping, monitoring , reporting and
emission control requirements of Regulation 7, Section XII . The operator shall comply
with all applicable requirements of Section XII .
20 Point 002: 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)
21 . Point 002: The owner or operator shall follow loading procedures that minimize the
leakage of VOCs to the atmosphere including , but not limited to (Reference: Regulation
3, Part B, III . E) :
a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or
other liquid or vapor loss during loading and unloading .
AIRS ID: 123/9C89 Page 8 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
b. All compartment hatches (including thief hatches) shall be closed and latched at
all times when loading operations are not active, except for periods of
maintenance, gauging , or safety of personnel and equipment.
c. The owner or operator shall inspect loading equipment and operations on site at
the time of the inspection to ensure compliance with Condition 21 (a) and (b)
above. The inspections shall occur at least monthly. Each inspection shall be
documented in a log available to the Division on request.
22. Point 002: 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.
23. Point 005: This source is subject to Regulation No. 7, Section XII .C General Provisions
(State only enforceable). All condensate collection , storage, processing and handling
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. The operator shall comply with all applicable requirements of Section
XII .
24 . Point 005: Minor sources in designated nonattainment or attainment/maintenance areas
that are otherwise not exempt pursuant to Section II . D. of Regulation No. 3 , Part B, shall
apply Reasonably Available Control Technology for the pollutants for which the area is
nonattainment or attainment/maintenance (Reference: Regulation No. 3, Park B,
IIl . D.2.a). Directed Inspection & Maintenance (DI&M), as required by Condition No. 25,
shall satisfy the requirement to apply Reasonably Available Control Technology (RACT) .
25 Point 005: Minor sources in designated nonattainment or attainment/maintenance areas
that are otherwise not exempt pursuant to Section 11 . D. of Regulation No. 3, Pad B, shall
apply Reasonably Available Control Technology (RACT) for the pollutants for which the
area is nonattainment or attainment/maintenance (Reference: Regulation No. 3 , Pad B,
IIl . D.2. a). This requirement to apply RACT shall be satisfied by implementing the
following Leak Detection and Repair (LDAR) program:
a. Leak Monitoring
i . Shall be completed on all components as defined per Regulation 7,
Section XVII .A.5;
ii . Approved Instrument Monitoring Methods (AIMM) as defined in
Regulation 7, Section XVIl .A.2 shall be evaluated according to the
provisions of Regulation 7, Section XVII . F.3.d and inspections
performed at the frequencies established in Section XVII . F.3 Table 3;
iii. Initial AIMM inspections shall be completed within 60 days of
commencement of operation;
iv. If a component is unsafe, difficult, or inaccessible to monitor per
Regulation 7, Section XVII .F.5, the owner or operator is not required
to monitor the component until it becomes feasible to do so.
b. Leaks requiring repair: Leaks must be identified utilizing the methods listed in this
condition. Only leaks detected pursuant to this condition require repair.
i. For EPA Method 21 monitoring , or other Division approved
quantitative instrument based monitoring, at facilities constructed
AIRS ID: 123/9C89 Page 9 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
before May 1 , 2014, a leak is any concentration of hydrocarbon above
2, 000 parts per million (ppm) not associated with normal equipment
operation , such as pneumatic device actuation and crank case
ventilation , except for well production facilities where a leak is defined
as any concentration of hydrocarbon above 500 ppm not associated
with normal equipment operation, such as pneumatic device actuation
and crank case ventilation .
ii. For EPA Method 21 monitoring, or other Division approved
quantitative instrument based monitoring , at facilities constructed on
or after May 1 , 2014, a leak is any concentration of hydrocarbon
above 500 ppm not associated with normal equipment operation , such
as pneumatic device actuation and crank case ventilation .
iii. For infra-red camera and AVO monitoring, or other Division approved
non-quantitative instrument based monitoring , a leak is any detectable
emissions not associated with normal equipment operation, such as
pneumatic device actuation and crank case ventilation .
iv. For leaks identified using an approved instrument monitoring method
or AVO, owners or operators have the option of either repairing the
leak in accordance with the repair schedule set forth in this condition.
or conducting follow-up monitoring using EPA Method 21 within five
(5) working days of the leak detection . If the follow-up EPA Method 21
monitoring shows that the emission is a leak as defined in this
condition, the leak must be repaired and remonitored in accordance
with the leak repair and remonitoring provisions contained herein.
c. Leak Repairs and Remonitoring
i . First attempt to repair a leak must be made no later than five (5)
working days after discovery, unless parts are unavailable, the
equipment requires shutdown to complete repair, or other good cause
exists. If pads are unavailable, they must be ordered promptly and the
repair must be made within fifteen (15) working days of receipt of the
parts. If shutdown is required, the leak must be repaired during the
next scheduled shutdown . If delay is attributable to other good cause,
repairs must be completed within fifteen ( 15) working days after the
cause of delay ceases to exist.
ii . Within fifteen (15) working days of completion of a repair, the leak
must be remonitored to verify the repair was effective.
d . Recordkeeping : The owner or operator must maintain the following records for a
period of two (2) years and make them available to the Division upon request.
i . Documentation of the initial approved instrument monitoring method
inspection for new well production facilities;
ii . The date and site information for each inspection ;
iii. A list of the leaking components and the monitoring method(s) used to
determine the presence of the leak;
iv. The date of first attempt to repair the leak and , if necessary, any
additional attempt to repair the leak;
AIRS ID: 123/9089 Page 10 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
v. The date the leak was repaired;
vi . The delayed repair list, including the basis for placing leaks on the list;
vii . The date the leak was remonitored to verify the effectiveness of the
repair, and the results of the remonitoring ; and
viii. A list of components that are designated as unsafe, difficult, or
inaccessible to monitor and explanation stating why the component is
so designated, and the plan for monitoring such component(s) .
26 Points 006-009: This equipment is subject to the control requirements for stationary and
portable engines in the 8-hour ozone control area under Regulation No. 7 , Section
XVI . B.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst
shall be required.
27 Point 006-013: These engines may be subject to the control requirements for natural
gas-fired reciprocating internal combustion engines under Regulation No. 7 , Section
XVII . E (State only enforceable). The owner or operator of any natural gas-fired
reciprocating internal combustion engine that is either constructed or relocated to the
state of Colorado from another state after the date listed in the table below shall operate
and maintain each engine according to the manufacturer's written instructions or
procedures to the extent practicable and consistent with technological limitations and
good engineering and maintenance practices over the entire life of the engine so that it
achieves the emission standards required in the table below:
Maximum' Engine Construction or Emission Standard in g/hp-hr
HP Relocation Date NOx CO VOC
•
< 100HP Any N/A N/A N/A
≥100HP and January 1 , 2008 2.0 4.0 1 .0
<500HP January 1 , 2011 1 .0 2.0 0.7
•
≥500HP July 1 , 2007 2.0 4.0 1 .0
July 1 , 2010 1 .0 2.0 0.7
' Maximum engine horsepower is the nameplate rating of the engine and does not
account for deration .
Note: Per Regulation No. 7, Section XVII .B.4, internal combustion engines that are
subject to an emission standard or an emissions control requirement in a federal
maximum achievable control technology ("MACT") standard under 40 CFR Part 63, a
Best Available Control Technology ("BACT") limit, or a New Source Performance
Standard under40 CFR Part 60 are not subject to this Section XVII .
OPERATING & MAINTENANCE REQUIREMENTS
28 Points 001 , 003, 004, and 006-014: 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 your O&M plan are subject to
Division approval prior to implementation . (Reference: Regulation No . 3 , Part B, Section
III . G .7.)
AIRS ID: 123/9C89 Page 11 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
29 Points 002 and 005: This source is not required to follow a Division-approved operating
and maintenance plan.
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
30 Point 001 : Within one hundred and eighty days (180) after commencement of operation,
the operator shall complete site specific sampling including a compositional analysis of
the pre-flash pressurized condensate routed to these storage tanks and a sales oil
analysis to determine RVP and API gravity. Testing shall be in accordance with the
guidance contained in PS Memo 05-01 . Results of testing shall be used to determine a
site-specific emissions factor using Division approved methods. Results of site-specific
sampling and analysis shall be submitted to the Division as part of the self-certification
and used to demonstrate compliance with the emissions factors chosen for this
emissions point.
31 Point 003: Within one hundred and eighty days (180) after commencement of operation,
the owner or operator shall complete an initial extended motive gas analysis and submit
the results to the Division as part of the self-certification process to ensure compliance
with emissions limits. (Reference: Regulation No. 3, Part B, Section III . E.)
32 Point 004: Within one hundred and eighty days (180) after commencement of operation,
the operator shall complete an initial site specific extended gas analysis of the natural
gas produced at this site in order to verify the VOC, benzene, toluene, ethylbenzene,
xylenes, n-hexane, and 2 ,2,4-trimethylpentane content (weight fraction) of this emission
stream used in the permit application . Results of testing shall be used to determine site-
specific emission factors using Division approved methods. Results of site-specific
sampling and analysis shall be submitted to the Division as part of the self-certification
and used to demonstrate compliance with the emissions factors chosen for this
emissions point.
33 Point 005: Within one hundred and eighty days (180) after commencement of operation,
the owner or operator shall complete the initial extended gas analysis of gas samples
that are representative of volatile organic compound (VOC) that may be released as
fugitive emissions. This extended gas analysis shall be used in the compliance
demonstration as required in the Emission Limits and Records section of this permit.
The operator shall submit the results of the gas analysis and emission calculations to the
Division as part of the self-certification process to ensure compliance with emissions
limits.
34. Point 005: Within one hundred and eighty days ( 180) after commencement of operation,
the operator shall complete a hard count of components at the source and establish the
number of components that are operated in "heavy liquid service", "light liquid service",
"water/oil service" and "gas service". The operator shall submit the results to the
Division as part of the self-certification process to ensure compliance with emissions
limits.
35 Points 006-009: Within one hundred and eighty days ( 180) after commencement of
operation, a source initial compliance test shall be conducted on emissions points 006-
009 to measure the emission rate(s) for the pollutants listed below in order to
demonstrate compliance with the emission limits in this permit. The test protocol must
be in accordance with the requirements of the Air Pollution Control Division Compliance
AIRS ID: 123/9C89 Page 12 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
Test Manual and shall be submitted to the Division for review and approval at least thirty
(30) days prior to testing. No compliance test shall be conducted without prior approval
from the Division. Any compliance test conducted to show compliance with a monthly or
annual emission limitation shall have the results projected up to the monthly or annual
averaging time by multiplying the test results by the allowable number of operating hours
for that averaging time (Reference: Regulation No . 3, Part B. , Section III .G .3)
Oxides of Nitrogen using EPA approved methods.
Carbon Monoxide using EPA approved methods.
Formaldehyde
36 Point 012-013: Within one hundred and eighty days (180) after commencement of
operation , a source initial compliance test shall be conducted on emissions points 012
and 013 to measure the emission rate(s) for the pollutants listed below in order to
demonstrate compliance with the emission limits in this permit. The test protocol must
be in accordance with the requirements of the Air Pollution Control Division Compliance
Test Manual and shall be submitted to the Division for review and approval at least thirty
(30) days prior to testing . No compliance test shall be conducted without prior approval
from the Division. Any compliance test conducted to show compliance with a monthly or
annual emission limitation shall have the results projected up to the monthly or annual
averaging time by multiplying the test results by the allowable number of operating hours
for that averaging time (Reference: Regulation No. 3, Part B. , Section III .G .3)
Oxides of Nitrogen using EPA approved methods.
Carbon Monoxide using EPA approved methods.
37 Point 014: Within one hundred and eighty days (180) after commencement of operation,
the operator shall complete an initial site specific extended gas analysis of the natural
gas produced at this site in order to verify the VOC, benzene, toluene, ethylbenzene,
xylenes, n-hexane, and 2,2,4-trimethylpentane content (weight fraction) of this emission
stream used in the permit application . Results of testing shall be used to determine site-
specific emission factors using Division approved methods. Results of site-specific
sampling and analysis shall be submitted to the Division as pad of the self-certification
and used to demonstrate compliance with the emissions factors chosen for this
emissions point.
38 Point 014: Within one hundred and eighty days (180) after commencement of operation,
the owner or operator shall demonstrate compliance with opacity standards, using EPA
Method 9 to measure opacity from the flare. (Reference: Regulation No. 1 , Section II .A. 1
& 4)
Periodic Testing Requirements
39 Point 005: On an annual basis, the owner or operator shall complete an extended gas
analysis of gas samples that are representative of volatile organic compounds (VOC)
and hazardous air pollutants (HAP) that may be released as fugitive emissions. This
extended gas analysis shall be used in the compliance demonstration as required in the
Emission Limits and Records section of this permit.
40 Point 006-013: These engines are subject to the periodic testing requirements as
specified in the operating and maintenance (O&M) plan as approved by the Division.
Revisions to your O&M plan are subject to Division approval. Replacements of this unit
completed as Alternative Operating Scenarios may be subject to additional testing
requirements as specified in Attachment A.
AIRS ID: 123/9C89 Page 13 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
ALTERNATE OPERATING SCENARIOS
41 Point 003: 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 capadty as authorized in this permit.
42 Point 003: 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.
43 Point 003: 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
44. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, II .C)
a. Annually by April 30'" 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 V0C or NOX per
year, a change in annual actual emissions of one (1 ) ton per year or more or five
percent, whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions
of five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted ; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less,
above the level reported on the last APEN submitted to the Division .
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed , or whenever a different type of
control equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
f. Points 006-014: Within 14 calendar days of commencing operation of a
permanent replacement engine under the alternative operating scenario outlined
in this permit as Attachment A. The APEN shall include the specific
manufacturer, model and serial number and horsepower of the permanent
replacement engine, the appropriate APEN filing fee and a cover letter explaining
AIRS ID: 123/9089 Page 14 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
that the owner or operator is exercising an alternative-operating scenario and is
installing a permanent replacement engine.
45 Federal regulatory program requirements (i .e. PSD, NANSR or Title V Operating Permit)
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 No. 3
Part D) .
46 MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil
and Natural Gas Production Facilities major stationary source requirements shall apply
to this stationary source at any such time that this stationary source becomes major
solely by virtue of a relaxation in any permit limitation and shall be subject to all
appropriate applicable requirements of Subpart HH . (Reference: Regulation No. 8, Part
E)
GENERAL TERMS AND CONDITIONS
47 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 No. 3, Part B, Section II . B upon a request for transfer of ownership
and the submittal of a revised APEN and the required fee.
48 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 No . 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.
49 . 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.
50 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.
51 . 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
AIRS ID: 123/9C89 Page 15 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
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.
52. 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.
53. 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: t -\1•-• ,_�,la. (40( 4-k.
Oluwaseun Ogungbenle
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Bonanza Creek Energy Operating
Company LLC for equipment at a new
compressor station.
AIRS ID: 12319C89 Page 16 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder at the time of this permit issuance:
1 ) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 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: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE-
Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641 &pagename=CBONWra pper
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
Emission Are the Controlled
AIRS Rate emissions Emission Rate
Point Pollutant CAS # (Ib/yr) reportable? (Ib/yr)
Benzene 71432 --- No ---
001
n-Hexane 110543 0.5 No 0
Benzene 71432 209 No 209
n-Hexane 110543 3813 Yes 3813
002
Toluene 108883 445 Yes 445
Xylenes 1330207 204 No 204
Benzene 71432 180 No 9
n-Hexane 110543 3099 Yes 155
003 Toluene 108883 139 No 7
Ethylbenzene 100414 21 No 1
Xylenes 1330207 52 Yes 3
Benzene 71432 173,711 Yes 434
n-Hexane 110543 3,263,523 Yes 8, 159
004 Toluene 108883 116,806 Yes 292
Ethylbenzene 100414 7,884 Yes 20
Xylenes 1330207 17,237 Yes 43
-
AIRS ID: 123/9C89 Page 17 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
Benzene 71432 77 No 77
n-Hexane 110543 1 ,376 Yes 1376
005 Toluene 108883 125 No 125
Ethylbenzene 100414 22 No 22
Xylenes 1330207 55 No 55
Benzene 71432 40 No 40
Toluene 108883 51 No 51
Formaldehyde 50000 9,004 Yes 3,601
006 Acetaldehyde 75070 763 Yes 763
Acrolein 107028 469 Yes 469
Methanol 67561 228 No 228
n-Hexane 110543 100 No 100
Benzene 71432 40 No 40
Toluene 108883 51 No 51
Formaldehyde 50000 9,004 Yes 3,601
007 Acetaldehyde 75070 763 Yes 763
Acrolein 107028 469 Yes 469
Methanol 67561 228 No 228
n-Hexane 110543 100 No 100
Benzene 71432 40 No 40
Toluene 108883 51 No 51
Formaldehyde 50000 9,004 Yes 3,601
008 Acetaldehyde 75070 763 Yes 763
Acrolein 107028 469 Yes 469
Methanol 67561 228 No 228
n-Hexane 110543 100 No 100
Benzene 71432 40 No 40
Toluene 108883 51 No 51
Formaldehyde 50000 9,004 Yes 3,601
009 Acetaldehyde 75070 763 Yes 763
Acrolein 107028 469 Yes 469
Methanol 67561 228 No 228
n-Hexane 110543 100 No 100
010 Benzene 71432 16 No 16
AIRS ID: 123/9C89 Page 18 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
Formaldehyde 50000 210 No 210
Benzene 71432 16 No 16
011
Formaldehyde 50000 210 No 210
Benzene 71432 29 No 29
Formaldehyde 50000 1 ,448 Yes 1448
012 Acetaldehyde 75070 52 No 52
Acrolein 107028 49 No 49
Methanol 67561 57 No 57
Benzene 71432 29 No 29
Formaldehyde 50000 1 ,448 Yes 1448
013 Acetaldehyde i 75070 52 No 52
Acrolein 107028 49 No 49
Methanol 67561 57 No 57
Benzene 71432 274 Yes 14
n-Hexane 110543 4,716 Yes 236
014 Toluene 108883 212 No 11
Ethylbenzene 100414 32 No 2
Xylenes 1330207 79 No 4
5) The emission levels contained in this permit are based on the following emission factors:
Point 001 :
Emission Factors Emission Factors
Uncontrolled Controlled
Pollutant lb/BBL lb/BBL Source
Condensate Condensate
Throughput Throughput
VOC 0.2 0.01 ProMax
n-Hexane 1 . 15E-05 Neg. ProMax
Benzene 4.08E-07 Neg. ProMax
Note: The controlled emissions for this point are based on the flare control efficiency of 95%.
Point 002:
Emission Factors - Uncontrolled
Pollutant lb/BBL loaded I Source
VOC 0.32 AP-42
Benzene 0.005 Engineering Estimate
n-Hexane 0.09 Engineering Estimate
AIRS ID: 12319C89 Page 19 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
Emission Factors - Uncontrolled
Pollutant lb/BBL loaded Source
Toluene 0.01 Engineering Estimate
Xylenes 0.005 Engineering Estimate
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*S*P*M/T
S = 0.6 (Submerged loading: dedicated normal service)
P (true vapor pressure) = 8.04 psia
M (vapor molecular weight) = 65.93 Ib/lb-mol
T (temperature of liquid loaded) = 524 °R
The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by
multiplying the mass fraction of each NCRP in the liquid by the VOC emission factor.
Point 003:
Emission Emission
Factors - Factors -
Uncontrolled Controlled
Pollutant lb/MMscf vented lb/MMscf vented Source
NOx 0.068 0.068 AP-42
(lb/MMBTU)
CO 0.37 0.37 AP-42
(lb/MMBTU)
VOC 21834.71 1091 .74 Gas Analysis
Benzene 34.30 1 .72 Gas Analysis
n-Hexane 589.55 29.48 Gas Analysis
Toluene 26.48 1 .32 Gas Analysis
Xylenes 9.89 0.49 Gas Analysis
Point 004:
Weight Emission Emission
Pollutant Fraction of Factors Factors Source
Gas r/o) Uncontrolled Controlled
lb/MMscf lb/MMscf
NOx 0.068 0.068 AP-42
(lb/MMBTU)
CO 0.37 0.37 AP-42
(lb/MMBTU)
VOC 96.70 166858.40 8342.92 Gas Analysis
Benzene 1 .10 1903.70 95.19 Gas Analysis
Toluene 0.74 1280.10 64.01 Gas Analysis
Ethylbenzene 0.05 86.40 4.32 Gas Analysis
Xylenes 0.11 188.90 9.45 Gas Analysis
AIRS ID: 123/9O89 Page 20 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
Weight Emission Emission
Pollutant Fraction of Factors Factors Source
Gas (%) Uncontrolled Controlled
Ib/MMscf Ib/MMscf
n-hexane 20.73 35764.60 1788.23 Gas Analysis
Emission estimates are based on a 100% collection efficiency when the gas is captured by the
VRU and a 95% control efficiency when it is sent to the enclosed flares.
Point 005:
Component Gas Heavy Oil Light Oil Water/Oil
Connectors 986 0 64 14
Flanges 372 0 56 23
Open-ended Lines 42 0 3 0
Pump Seals 9 0 0 3
Valves 392 0 48 15
Other 70 0 3 0
VOC Content (wt. 0.3366 0 0.9996 1 .0000
fraction)
Benzene Content (wt. 0.0005 0 0.0150 0.0001
fraction)
Toluene Content (wt. 0.0004 0 0.0319 0.0012
fraction)
Ethylbenzene (wt. 0.0001 0 0.0058 0.0003
fraction)
Xylenes Content (wt. 0.0002 0 0.0146 0.0001
fraction)
n-hexane Content (wt. 0.0091 0 0.2740 0.0001
fraction)
*Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms,
drains, dump arms, hatches, instrument meters, polish rods and vents
TOC Emission Factors (kg/hr-component):
Water/Oil
Component Gas Service Heavy Oil Light Oil
Service
Connectors 2.0E-04 7.5E-06 2.1E-04 1 .1E-04
Flanges 3.9E-04 3.9E-07 1 .1E-04 2.9E-06
Open-ended Lines 2.0E-03 1 .4E-04 1 .4E-03 2.5E-04
Pump Seals 2.4E-03 NA 1 .3E-02 2.4E-05
Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05
Other 8.8E-03 3.2E-05 7.5E-03 1 .4E-02
Source: EPA-453/R-95-017 Table 2-4
Compliance with emissions limits in this permit will be demonstrated by using the TOC emission
factors listed in the table above with representative component counts, multiplied by the VOC content
from the most recent gas analysis.
AIRS ID: 123/9C89 Page 21 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
Point 006:
Pollutant Emission Factors - Emission Factors — Source
Uncontrolled Controlled
NOx 0.50 g/hp-hr 0.50 g/hp-hr Manufacturer
CO 3.11 g/hp-hr 1 .00 _ g/hp-hr Manufacturer
VOC 1 .38 g/hp-hr 0.70 g/hp-hr Manufacturer
Formaldehyde 0.36 g/hp-hr 0.144 _ g/hp-hr Manufacturer
Acetaldehyde 0.0084 lb/MMBTU 0.0084 lb/MMBTU AP-42
Acrolein 0.0051 lb/MMBTU 0.0051 lb/MMBTU AP-42
Benzene 0.0004 lb/MMBTU 0.0004 lb/MMBTU AP-42
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 8050 Btu/hp-hr, a
site-rated horsepower value of 1295, and a fuel heat value of 1403 Btu/scf.
Point 007:
Pollutant Emission Factors - Emission Factors — Source
Uncontrolled Controlled
NOx 0.50 g/hp-hr 0.50 g/hp-hr Manufacturer
CO 3. 11 g/hp-hr 1 .00 g/hp-hr Manufacturer
VOC 1 .38 g/hp-hr 0.70 g/hp-hr Manufacturer
Formaldehyde 0.36 g/hp-hr 0. 144 g/hp-hr Manufacturer
Acetaldehyde 0.0084 lb/MMBTU 0.0084 Ib/MMBTU AP-42
Acrolein 0.0051 lb/MMBTU 0.0051 lb/MMBTU AP-42
Benzene 0.0004 lb/MMBTU 0.0004 lb/MMBTU AP-42
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 8050 Btu/hp-hr, a
site-rated horsepower value of 1295, and a fuel heat value of 1403 Btu/scf.
Point 008:
Emission Factors - Emission Factors — Source
Pollutant
Uncontrolled Controlled
NOx 0.50 g/hp-hr 0.50 g/hp-hr Manufacturer
CO 3.11 g/hp-hr 1 .00 g/hp-hr Manufacturer
VOC 1 .38 g/hp-hr 0.70 g/hp-hr Manufacturer
Formaldehyde 0.36 g/hp-hr 0.144 g/hp-hr Manufacturer
Acetaldehyde 0.0084 lb/MMBTU 0.0084 lb/MMBTU AP-42
Acrolein 0.0051 lb/MMBTU 0.0051 lb/MMBTU AP-42
Benzene 0.0004 lb/MMBTU 0.0004 lb/MMBTU AP-42
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 8050 Btu/hp-hr, a
site-rated horsepower value of 1295, and a fuel heat value of 1403 Btu/scf.
Point 009:
Pollutant Emission Factors - Emission Factors — Source
Uncontrolled Controlled
NOx 0.50 _ g/hp-hr 0.50 g/hp-hr Manufacturer
CO 3. 11 g/hp-hr 1 .00 g/hp-hr Manufacturer
VOC 1 .38 g/hp-hr 0.70 g/hp-hr Manufacturer
Formaldehyde 0.36 g/hp-hr 0.144 g/hp-hr Manufacturer
AIRS ID: 123/9C89 Page 22 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
Emission Factors - Emission Factors — Source
Pollutant
Uncontrolled Controlled
Acetaldehyde 0.0084 Ib/MMBTU 0.0084 lb/MMBTU AP-42
Acrolein 0.0051 lb/MMBTU 0.0051 lb/MMBTU AP-42
Benzene 0.0004 lb/MMBTU 0.0004 lb/MMBTU AP-42
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 8050 Btu/hp-hr, a
site-rated horsepower value of 1295, and a fuel heat value of 1403 Btu/scf.
Point 010:
Pollutant Emission Factors - Emission Factors — Source
Uncontrolled Controlled
NOx 2.21 lb/MMBTU 1 .00 g/hp-hr AP-42
CO 3.72 Ib/MMBTU 2.00 g/hp-hr AP-42
VOC 0.70 g/hp-hr 0.70 g/hp-hr NSPS JJJJ
Formaldehyde 0.0205 lb/MMBTU 0.0205 Ib/MMBTU AP-42
Acetaldehyde 0.0028 lb/MMBTU 0.0028 lb/MMBTU AP-42
Acrolein 0.0026 lb/MMBTU 0.0026 lb/MMBTU AP-42
Benzene 0.0016 lb/MMBTU 0.0016 lb/MMBTU AP-42
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 9000 Btu/hp-hr, a
site-rated horsepower value of 130, and a fuel heat value of 1403 Btu/scf.
Point 011 :
Pollutant Emission Factors - Emission Factors — Source
Uncontrolled Controlled
NOx 2.21 lb/MMBTU 1 .00 g/hp-hr AP-42
CO 3.72 lb/MMBTU 2.00 g/hp-hr AP-42
VOC 0.70 g/hp-hr 0.70 g/hp-hr NSPS JJJJ
Formaldehyde 0.0205 lb/MMBTU 0,0205 lb/MMBTU AP-42
Acetaldehyde 0.0028 lb/MMBTU 0.0028 lb/MMBTU AP-42
Acrolein 0.0026 lb/MMBTU 0.0026 lb/MMBTU AP-42
Benzene 0.0016 lb/MMBTU 0.0016 lb/MMBTU AP-42
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 9000 Btu/hp-hr, a
site-rated horsepower value of 130, and a fuel heat value of 1403 Btu/scf.
Point 012:
Pollutant Emission Factors - Emission Factors — Source
Uncontrolled Controlled
NOx 2.21 lb/MMBTU 1 .00 g/hp-hr AP-42
CO 3.72 lb/MMBTU 2.00 g/hp-hr AP-42
VOC 0.70 g/hp-hr 0.70 g/hp-hr NSPS JJJJ
Formaldehyde 0.30 g/hp-hr 0.30 g/hp-hr NSPS JJJJ
Acetaldehyde 0.0028 lb/MMBTU 0.0028 Ib/MMBTU AP-42
Acrolein 0.0026 lb/MMBTU 0.0026 lb/MMBTU AP-42
Benzene 0.0016 lb/MMBTU 0.0016 Ib/MMBTU AP-42
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 8500 Btu/hp-hr, a
site-rated horsepower value of 250, and a fuel heat value of 1403 Btu/scf.
AIRS ID: 12319C89 Page 23 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
Point 013:
Emission Factors - Emission Factors — Source
Pollutant
Uncontrolled Controlled
NOx 2.21 lb/MMBTU 1 .00 g/hp-hr AP-42
CO 3.72 Ib/MMBTU 2.00 g/hp-hr AP-42
VOC 0.70 g/hp-hr 0.70 g/hp-hr NSPS JJJJ
Formaldehyde 0.30 g/hp-hr 0.30 g/hp-hr NSPS JJJJ
Acetaldehyde 0.0028 Ib/MMBTU 0.0028 lb/MMBTU AP-42
Acrolein 0.0026 Ib/MMBTU 0.0026 lb/MMBTU AP-42
Benzene 0.0016 Ib/MMBTU 0.0016 lb/MMBTU AP-42
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 8500 Btu/hp-hr, a
site-rated horsepower value of 250, and a fuel heat value of 1403 Btu/scf.
Point 014:
Weight Emission Emission
Pollutant Fraction of Factors Factors Source
Gas r/o) Uncontrolled Controlled
lb/MMscf lb/MMscf
NOx --- 0.068 0.068 AP-42
(lb/MMBTU)
CO --- 0.37 0.37 AP-42
(lb/MMBTU)
VOC 33.66 21834.70 1091 .74 Gas Analysis
Benzene 0.05 34.30 1 .72 Gas Analysis
Toluene 0.04 26.50 1 .33 Gas Analysis
Ethylbenzene 0.01 4.00 0.20 Gas Analysis
Xylenes 0.02 9.90 0.50 Gas Analysis
n-hexane 0.91 589.50 29.48 Gas Analysis
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) Points 006-013: These engines may be subject to 40 CFR, Part 60, Subpart JJJJ—Standards of
Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008
Federal Register posting — effective March 18, 2008). This rule has not yet been incorporated into
Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is
available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ia08.pdf
8) Points 006-013: This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission
Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See
January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008
amendments to include requirements for area sources and engines ≤ 500 hp located at major
sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation
No. 8. A copy of the complete subpart is available on the EPA website at:
http://www.epa.gov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards
can be found on the EPA website at: http://www.epa.qov/ttn/atw/area/arearules.html
AIRS ID: 123/9C89 Page 24 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
9) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of VOC, CO, Benzene, Toluene, Formaldehyde,
n-Hexane, and total HAPs
NANSR Synthetic Minor Source of VOC
PSD Synthetic Minor Source of CO
NSPS Kb Not Applicable
NSPS OOOO Not Applicable
MACT HH Major Source Requirements: Not Applicable
Area Source Requirements: Applicable
10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60 : Standards of Performance for New Stationary Sources
NSPS 60. 1 -End Subpart A — Subpart KKKK
NSPS Part 60, Appendixes Appendix A — Appendix I
Part 63 : National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT 63. 1 -63.599 Subpart A — Subpart Z
MACT 63 .600-63. 1199 Subpart AA - Subpart DDD
MACT 63. 1200-63. 1439 Subpart EEE — Subpart PPP
MACT 63. 1440-63.6175 Subpart QQQ — Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ — Subpart M MMM M
MACT 63.8980-End Subpart NNNNN — Subpart XXXXXX
11 ) A self certification form and guidance on how to self-certify compliance as required by this permit may
be obtained online at: http://www.colorado.qov/pacific/cdphe/air-permit-self-certification
AIRS ID: 123/9C89 Page 25 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
ATTACHMENT A:
ALTERNATIVE OPERATING SCENARIOS
RECIPROCATING INTERNAL COMBUSTION ENGINES
October 12, 2012
2. Alternative Operating Scenarios
The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of
natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the
requirements of Regulation No. 3., Part Al Section IV.A, Operational Flexibility-Alternative Operating
Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary
Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all
applicable substantive and procedural requirements. This permit incorporates and shall be considered a
Construction Permit for any engine replacement performed in accordance with this AOS, and the owner
or operator shall be allowed to perform such engine replacement without applying for a revision to this
permit or obtaining a new Construction Permit.
2.1 Engine Replacement
The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown
or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a
temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90
operating days or less in any 12 month period. "Permanent" is defined as in the same service for more
than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is
in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90
day total. The compliance demonstrations and any periodic monitoring required by this AOS are in
addition to any compliance demonstrations or periodic monitoring required by this permit.
All replacement engines are subject to all federally applicable and state-only requirements set forth in this
permit (including monitoring and record keeping).
The results of all tests and the associated calculations required by this AOS shall be submitted to the
Division within 30 calendar days of the test or within 60 days of the test if such testing is required to
demonstrate compliance with NSPS or MACT requirements.
Results of all tests shall be kept on site for five (5) years and made available to the Division upon request.
The owner or operator shall maintain a log on-site and contemporaneously record the start and stop date
of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and
serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer,
model number, horsepower, and serial number of the replacement engine. In addition to the log, the
owner or operator shall maintain a copy of all Applicability Reports required under section 2. 1 .2 and make
them available to the Division upon request.
2.1 .1 The owner or operator may temporarily replace an existing compressor engine that is subject to
the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and
horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying
this permit, so long as the temporary replacement engine complies with all permit limitations and other
requirements applicable to the existing engine. Measurement of emissions from the temporary
replacement engine shall be made as set forth in section 2.2.
AIRS ID: 123/9C89 Page 26 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
2. 1 .2 The owner or operator may permanently replace the existing compressor engine with another
engine with the same manufacturer, model, and horsepower engines without modifying this permit so
long as the permanent replacement engine complies with all permit limitations and other requirements
applicable to the existing engine as well as any new applicable requirements for the replacement engine.
Measurement of emissions from the permanent replacement engine and compliance with the applicable
emission limitations shall be made as set forth in section 2.2.
An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial
number and horsepower of the permanent replacement engine shall be filed with the Division for the
permanent replacement engine within 14 calendar days of commencing operation of the replacement
engine. The AP EN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that
the owner or operator is exercising an alternative operating scenario and is installing a permanent
replacement engine, and a copy of the relevant Applicability Reports for the replacement engine.
Example Applicability
Reports can be found at http://www.cdphe.state.co. us/ap/oilgaspermitting .html . This submittal shall be
accompanied by a certification from the Responsible Official indicating that "based on the information and
belief formed after reasonable inquiry, the statements and information included in the submittal are true,
accurate and complete".
This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine
or an engine that is not subject to emission limits.
The owner or operator shall agree to pay fees based on the normal permit processing rate for review of
information submitted to the Division in regard to any permanent engine replacement.
2.2 Portable Analyzer Testing
Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping
Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss
streamlining the testing requirements.
Note that the testing required by this Condition may be used to satisfy the periodic testing requirements
specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer
testing, this test conducted under the AOS will serve as the quarterly test and an additional portable
analyzer test is not required for another three months).
The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required
by this Condition, if approved in advance by the Division.
The owner or operator shall measure nitrogen oxide (NOx) and carbon monoxide (CO) emissions in the
exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of
commencing operation of the replacement engine.
All portable analyzer testing required by this permit shall be conducted using the Division's Portable
Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at:
http://www.colorado.gov/cs/Satellite/CDPHE-AP/CBON/1251596520270.
Results of the portable analyzer tests shall be used to monitor the compliance status of this unit.
For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the
tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or
year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation
the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever
applies.
AIRS ID: 123/9O89 Page 27 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
For comparison with a short-term limit that is either input based (Ib/MMBtu), output based (g/hp-hr) or
concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement
engine will be subject to, the results of the test shall be converted to the appropriate units as described in
the above-mentioned Portable Analyzer Monitoring Protocol document.
If the portable analyzer results indicate compliance with both the NOx and CO emission limitations, in the
absence of credible evidence to the contrary, the source may certify that the engine is in compliance with
both the NOx and CO emission limitations for the relevant time period.
Subject to the provisions of C .R.S. 25-7-123. 1 and in the absence of credible evidence to the contrary, if
the portable analyzer results fail to demonstrate compliance with either the NOx or CO emission
limitations, the engine will be considered to be out of compliance from the date of the portable analyzer
test until a portable analyzer test indicates compliance with both the NOx and CO emission limitations or
until the engine is taken offline.
2.3 Applicable Regulations for Permanent Engine Replacements
2.3. 1 Reasonably Available Control Technology (RACT): Reg. 3, Part B § II. D .2
All permanent replacement engines that are located in an area that is classified as
attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT)
for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and
NON are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which
the area is in attainment/maintenance or nonattainment, except as follows:
In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of
emissions and to NOx and SO2, as precursors to PM10, if the potential to emit of NOx or SO2 exceeds 40
tons/yr.
For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating
internal combustion engines:
VOC: The emission limitations in NSPS JJJJ
CO: The emission limitations in NSPS JJJJ
NON: The emission limitations in NSPS JJJJ
SO2: Use of natural gas as fuel
PM10: Use of natural gas as fuel
As defined in 40 CFR Pad 60 Subparts GG (§ 60.331 ) and 40 CFR Part 72 (§ 72.2) , natural gas contains
20.0 grains or less of total sulfur per 100 standard cubic feet.
2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII .E (State-
Only conditions).
Control Requirements: Section XVI
Any permanent replacement engine located within the boundaries of an ozone nonattainment area is
subject to the applicable control requirements specified in Regulation No. 7, section XVI , as specified
below:
Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non-
selective catalyst and air fuel controller to reduce emission.
Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation
catalyst to reduce emissions.
AIRS ID: 123/9O89 Page 28 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
The above emission control equipment shall be appropriately sized for the engine and shall be operated
and maintained according to manufacturer specifications.
The source shall submit copies of the relevant Applicability Reports required under Condition 2. 1 .2.
Emission Standards: Section XVII.E -- State-only requirements
Any permanent engine that is either constructed or relocated to the state of Colorado from another state,
after the date listed in the table below shall operate and maintain each engine according to the
manufacturer's written instructions or procedures to the extent practicable and consistent with
technological limitations and good engineering and maintenance practices over the entire life of the
engine so that it achieves the emission standards required in the table below:
Construction or Emission Standards in G/hp-hr
Max Engine HP Relocation Date
NOX CO VOC
January 1 , 2008 2.0 4.0 1 .0
1Q0<Hp<500 January 1 , 2011 1 .0 2.0 0.7
July 1 , 2007 2.0 4.0 1 .0
500≤Hp July 1 , 2010 1 .0 2.0 0.7
The source shall submit copies of the relevant Applicability Reports required under Condition 2.1 .2.
2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ
A permanent replacement engine that is manufactured on or after 7/1 /09 for emergency engines greater
than 25 hp, 7/1 /2008 for engines less than 500 hp, 7/1 /2007 for engines greater than or equal to 500 hp
except for lean burn engines greater than or equal to 500 hp and less than 1 ,350 hp, and 1/1 /2008 for
lean burn engines greater than or equal to 500 hp and less than 1 ,350 hp are subject to the requirements
of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting
requirements for the permanent engine replacement shall be included in the Applicability Reports
required under Condition 2.1 .2. Any testing required by the NSPS is in addition to that required by this
AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this
AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted
within the time frame specified in Condition 2.2.
Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from
outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to
the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes
equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ
requirements).
However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does,
any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ,
there will be an additional step added to the determination of the NSPS. Under the provisions of
Regulation No. 6, Part B, § 1.8 (which is referenced in Part A), any engine relocated from outside of the
State of Colorado into the State of Colorado is considered to be a new source, subject to the
requirements of NSPS JJJJ.
2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ
A permanent replacement engine located at either an area or major source is subject to the requirements
in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting
AIRS ID: 123/9C89 Page 29 of 30
Colorado Department of Public Health and Environment
Air Pollution Control Division
requirements for the permanent engine replacement shall be included in the Applicability Reports
required under Condition 2. 1 .2. Any testing required by the MACT is in addition to that required by this
AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under
Condition 2.2 , if approved in advance by the Division, provided that such test is conducted within the time
frame specified in Condition 2.2.
2.4 Additional Sources
The replacement of an existing engine with a new engine is viewed by the Division as the installation of a
new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an
advanced construction permit review. The AOS cannot be used for additional new emission points for any
site; an engine that is being installed as an entirely new emission point and not as part of an AOS-
approved replacement of an existing onsite engine has to go through the appropriate
Construction/Operating permitting process prior to installation,
AIRS ID: 123/9C89 Page 30 of 30
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