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Home My WebLink About20152919.tiff � � C4LORADO � ,� Department of Public � Health E�Envirc�nment Dedicated to protecting and improving the heafth and environment of the people of Co(orado Weld County - Clerk to the Board PO Box�5$ RECEIVED Greeley, CO 80632 AUG 3 1 Zu i� August 27, 2015 WELD COUNTY COMMISSION�R� Dear Sir or Madam: On September 2, 2015, the Air Pollution Controt Division will begin a 30-day public notice period for Bonanza Creek Energy Operating Company, LLC - Pronghorn 24-7 Booster Station. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health � Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, -�, � �� d , ��., �` .��,�; �: Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Controt Division Enclosure ��'�' '—" � 2015-2919 9� �� C. �'r.��r�� -g�� }. 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe ��w ��r, � �' John W. Hickenlooper, Govemor � Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer fr � ,��.`�_ �f �x 187fi,"'.� � � Air Pollution Controi Dzvision � Notice of a Proposed Project orActivity Warranting Public r� Comment Website Titte: Bonanza Creek Energy Operating Company, LLC - Pronghorn 24-7 Booster Station - Weld County Notice Period Begins: September 2, 2015 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: Pronghorn 24-7 Booster Station Natural gas compressor station SESW Sec 7 T5N R61 W Wetd County The proposed project or activity is as fotlows: The applicant proposes to construct a new 12.0 MMscf per day TEG dehydrator. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potentiat to emit in order to avoid other requirements The Division has made a pretiminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 14WE0521 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's anatysis are avaitable on the Division's website at https://www.cotorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby soticits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the appticable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Carissa Money Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcdC�state.co.us . . .. . . . . . . . ... . .. . . ...... . . . . , CAL4RAC74 1 � � _� ,,.. . , , DRAFT STATE OF COLORADO OF cO1O COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION Lei o TELEPHONE: (303)692-3150 /876 CONSTRUCTION PERMIT PERMIT NO: 14WE0521 Issuance 3 DATE ISSUED: 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 control 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 control 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 captured 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 control efficiency of 95%. 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 1 of 28 DRAFTColorado 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. FL-1 014 Equipment blowdown controlled by an emergency flare. Flare has a minimum control efficiency of 95%. The flare is not enclosed. One (1)Triethylene glycol (TEG) natural gas dehydration unit (make, model, serial number:to be determined)with a design capacity of 12.0 MMscf per day. This emissions unit is equipped with two (2) Kimray, model 21015 gas-glycol pumps, each with a design capacity of 3.5 gallons per minute. Only one Kimray gas- DEHY-1 015 glycol pump will be operated at any given time. The second Kimray gas-glycol pump serves as a back-up only. This unit is also equipped with a flash tank, reboiler and still vent. Emissions from the still vent are routed to an enclosed flare. Emissions from the flash tank are 100% recycled to the sales gas line or to the fuel gas system. 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 012-013: 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 AIRS ID: 123/9C89 Page 2 of 28 DRA FT Colorado Department of Public Health and Environment Air Pollution Control Division conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, II I.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline 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 012-013, 015: 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.) 6. Points 012-013: 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. 7. 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 8. 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 Equipment ID Point NO VOC CO Emission Type X CND TK 001 --- 358 --- Point TL 002 --- 1189 --- Point P-1 003 51 493 238 Point VRT 004 53 1612 284 Point G-1 012 408 289 815 Point AIRS ID: 123/9C89 Pa e 3 of 28 9 DRA FT Colorado Department of Public Health and Environment Air Pollution Control Division G-2 013 408 289 815 Point FL-1 014 68 747 360 Point DEHY-1 07 5 659 Poi nt (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 Ib/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3,398 Ib/month. Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO VOC CO Emission Type X CND TK 001 --- 2.1 -- Point TL 002 --- 7.0 -- Point P-1 003 0.3 2.9 1.4 Point VRT 004 0.3 9.5 1.7 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 DEHY-1 015 --- 3.9 --- Point See "Notes fo Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. During the first finrelve (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 AIRS ID: 123/9C89 Page 4 of 28 DRA F T Colorado Department of Public Health and Environment Air Pollution Control Division twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 9. Point 015: Compliance with the emission limits in this permit shall be demonstrated by running the GRI GlyCalc model version 4.0 or higher on a monthly basis using the most recent extended wet gas analysis and recorded operational values (including gas throughput, lean glycol recirculation rate, and other operational values specified in the O&M Plan). Recorded operational values, except for gas throughput, shall be averaged on a monthly basis for input into GRI GlyCalc and be provided to the Division upon request. 10. Point 015: 100% of emissions that result from the flash tank associated with this dehydrator shall be recycled to the sales gas line or fuel gas system. wi h the control 11. The emission points in the table below shall be operated and maintained t 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 II I.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 G-1 012 NSCR/AFRC NOx&CO G-2 013 NSCR/AFRC NOx&CO FL-1 014 Flare VOC& HAPs DEHY-1 015 Enclosed flare for the still vent VOC&HAPs PROCESS LIMITATIONS AND RECORDS 12. 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 BBUyr 3720 BBL/month TL 002 Condensate Loaded 43,800 BBL/yr 3720 BBUmonth P-1 003 Motive Gas Consumed 5.3 MMscf/yr 0.5 MMscf/month VRT 004 VRT Gas Vented 3.1 MMscf/yr 0.3 MMscf/month G-1 012 Consumption of natural gas as fuel 13.3 MMscf/yr 1.1 MMscf/month AIRS ID: 123/9C89 Page 5 of 28 DRA F T Colorado Department of Public Health and Environment Air Pollution Control Division 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 DEHY-1 015 Natural gas throughput 4,380 MMscf/yr 3�2 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. 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. 13. Point 015: This unit shall be limited to the maximum lean glycol circulation rate of 3.5 gallons per minute. The lean glycol recirculation rate shall be recorded as per the frequency required in the approved O&M Plan. This information shall be maintained in a log on site and made available to the Division for inspection upon request. (Reference: Regulation No. 3, Part B, II.A.4) STATE AND FEDERAL REGULATORY REQUIREMENTS 14. 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 003 and 004: No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (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. AIRS ID: 123/9C89 Page 6 of 28 DRAFTColorado Department of Public Health and Environment Air Pollution Control Division 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 001: The condensate storage tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: XVII.C.1.a. Beginning May 1, 2008, owners or operators of all atmospheric condensate storage tanks with uncontrolled actual emissions of volatile organic compounds equal to or greater than 20 tons per year based on a rolling twelve-month total shall operate air pollution control equipment that has an average control efficiency of at least 95%for VOCs on such tanks. 21. Points 001 and 015: The flare(s) covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). These requirements include, but are not limited to: XVII.B.2.b If a combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. XVI1.B.2.d Auto-igniters: All combustion devices used to control emissions of hydrocarbons must be equipped with and operate an auto-igniter as follows: XVI1.B.2.d.(i)All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto-igniter upon installation of the combustion device. XVIl.B.2.d. ii All combustion devices installed before May 1, 2014, must be equipped O with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 22. Point 001: The storage tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: Section XVII.C.1. Control and monitoring requirements for storage tanks XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of VOCs equal to or greater than six (6) tons per year based on a rolling twelve- month total must 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. XVII.C.1.b.(i) Control requirements of Section XVII.C.1.b.must be achieved in accordance with the following schedule: XVII.C.1.b.(i)(a) A storage tank constructed on or after May 1, 2014, must be in compliance within ninety (90) days of the date that the storage tank commences operation. XVII.C.1.b.(i)(b) A storage tank constructed before May 1, 2014, must be in compliance by May 1, 2015. AIRS ID: 123/9C89 Page 7 of 28 DRAFTColorado Department of Public Health and Environment Air Pollution Control Division XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks subject to Section XVII.C.1. must conduct audio, visual, olfactory ("AVO") and additional visual inspections of the storage tank and any associated equipment (e.g. separator, air pollution control equipment, or other pressure reducing equipment) at the same frequency as liquids are loaded out from the storage tank. These inspections are not required more frequently than every seven (7) days but must be conducted at least every thirty one (31) days. Monitoring is not required for storage tanks or associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e. The additional visual inspections must include, at a minimum: XVII.C.1.d.(i) Visual inspection of any thief hatch, pressure relief valve, or other access point to ensure that they are closed and properly sealed; XVII.C.1.d.(ii) Visual inspection or monitoring of the air pollution control equipment to ensure that it is operating, including that the pilot light is lit on combustion devices used as air pollution control equipment; XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto-igniter and valves for piping of gas to the pilot light to ensure they are functioning properly; XVII.C.1.d.(iv) Visual inspection of the air pollution control equipment to ensure that the valves for the piping from the storage tank to the air pollution control equipment are open; and XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the presence or absence of smoke. If smoke is observed, either the equipment must be immediately shut-in to investigate the potential cause for smoke and perform repairs, as necessary, or EPA Method 22 must be conducted to determine whether visible emissions are present for a period of at least one (1)minute in fifteen (15)minutes. XVII.C.1.e. If storage tanks or associated equipment is unsafe, difficult, or inaccessible to monitor, the owner or operator is not required to monitor such equipment until it becomes feasible to do so. XVII.C.2. Capture and monitoring requirements for storage tanks that are fitted with air pollution control equipment as required by Sections XII.D. or XVII.C.1. XVII.C.2.a. Owners or operators of storage tanks must route all hydrocarbon emissions to air pollution control equipment, and must operate without venting hydrocarbon emissions from the thief hatch (or other access point to the tank) or pressure relief device during normal operation, unless venting is reasonably required for maintenance, gauging, or safety of personnel and equipment. Compliance must be achieved in accordance with the schedule in Section XVII.C.2.b.(ii). XVII.C.2.b. Owners or operators of storage tanks subject to the control requirements of Sections XII.D.2., XVII.C.1.a, or XVII.C.1.b. must develop, certify, and implement a documented Storage Tank Emission Management System ("STEM") plan to identify, evaluate, and employ appropriate control technologies, monitoring practices, operational practices, and/or other strategies designed to meet the requirements set forth in Section XVII.C.2.a. Owners or operators must update AIRS ID: 123/9C89 Page 8 of 28 DRA F T Colorado Department of Public Health and Environment Air Pollution Control Division the STEM plan as necessary to achieve or maintain compliance. Owners or operators are not required to develop and implement STEM for storage tanks containing only stabilized liquids. The minimum elements of STEM are listed below. XVII.C.2.b.(i) STEM must include selected control technologies, monitoring practices, operational practices, and/or other strategies; procedures for evaluating ongoing storage tank emission capture performance; and monitoring in accordance with approved instrument monitoring methods following the applicable schedule in Section XVII.C.2.b.(ii) and Inspection Frequency in Table 1. XVII.C.2.b.(ii) Owners or operators must achieve the requirements of Sections XVII.C.2.a. and XVII.C.2.b. and begin implementing the required approved instrument monitoring method in accordance with the following schedule: XVII.C.2.b.(ii)(a) A storage tank constructed on or after May 1, 2014, must comply with the requirements of Section XVII.C.2.a. by the date the storage tank commences operation. The storage tank must comply with Section XVII.C.2.b. and implement the approved instrument monitoring method inspections within ninety (90) days of the date that the storage tank commences operation. XVII.C.2.b.(ii)(d) Following the first approved instrument monitoring method inspection, owners or operators must continue conducting approved instrument monitoring method inspections in accordance with the Inspection Frequency in Table 1. Table 1 —Storage Tank Inspections Threshold: Storage Tank Approved Instrument Phase-In Uncontrolled Actual VOC Monitoring Method Inspection Schedule Emissions (tpy) Frequency ?6 and≤ 12 Annually January 1, 2016 > 12 and < 50 Quarterly July 1, 2015 > 50 Monthly January 1, 2015 XVII.C.2.b.(iii) �wners or operators are not required to monitor storage tanks and associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e. XVII.C.2.b.(iv) STEM must include a certification by the owner or operator that the selected STEM strategy(ies) are designed to minimize emissions from storage tanks and associated equipment at the facility(ies), including thief hatches and pressure relief devices. XVII.C.3. Recordkeeping AIRS ID: 123/9C89 Page 9 of 28 DRA FT Colorado Department of Public Health and Environment Air Pollution Control Division XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or XVII.C. must maintain records of STEM, if applicable, including the plan, any' updates, and the certification, and make them available to the Division upon request. In addition, for a period of two (2) years, the owner or operator must maintain records of any required monitoring and make them available to the Division u on re uest, includin : P q 9 XVII.C.3.a. The AIRS ID for the storage tank. XVII.C.3.b. The date and duration of any period where the thief hatch, pressure relief device, or other access point are found to be venting hydrocarbon emissions, except for venting that is reasonably required for maintenance, gauging, or safety of personnel and equipment. XVII.C.3.c. The date and duration of any period where the air pollution control equipment is not operating. XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA Method 22 test or investigation pursuant to Section XVII.C.1.d.(v). XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air pollution control equipment, and mitigate visible emissions. XVII.C.3.f. A list of equipment associated with the storage tank that is designated as unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an explanation stating why the equipment is so designated, and the plan for monitoring such equipment. 23. 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, II I.E) 24. 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. 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 24 (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. 25. 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. 26. Point 012-013: 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 AIRS ID: 123/9C89 Page 10 of 28 DRA FT Colorado Department of Public Health and Environment Air Pollution Control Division 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 �uly 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 under 40 CFR Part 60 are not subject to this Section XVII. 27. Point 015: This equipment is subject to the control requirements for glycol natural gas dehydrators under Regulation No. 7, Section XII.H. Beginning May 1, 2005, uncontrolled actual emissions of volatile organic compounds from the still vent and vent from any gas- condensate-glycol (GCG) separator (flash separator or flash tank), if present, shall be reduced by at least 90 percent through the use of air pollution control equipment. This source shall comply with all applicable general provisions of Regulation 7, Section XI I. 28. Point 015: This equipment is subject to the control requirements for glycol natural gas dehydrators under Regulation No. 7, Section XVII.D. (State only enforceable). These requirements include, but are not limited ta XVII.D.3. Beginning May 1, 2015, still vents and vents from any flash separator or flash tank on a glycol natural gas dehydrator located at an oil and gas exploration and production operation, natural gas compressor station, or gas-processing plant subject to control requirements pursuant to Section XVII.D.4., shall reduce uncontrolled actual emissions of hydrocarbons by at least 95 percent on a rolling twelve-month basis through the use of a condenser or air pollution control equipment. If a combustion device is used, it shall have a design destruction efficiency of at least 98%for hydrocarbons. XVII.D.4. The control requirement in Section XVII.D.3. shall apply where: XVII.D.4.a. Uncontrolled actual emissions of VOCs from a glycol natural gas dehydrator constructed on or after May 1, 2015, are equal to or greater than two (2) tons per year. Such glycol natural gas dehydrators must be in compliance with Section XVII.D.3. by the date that the glycol natural gas dehydrator commences operation. AIRS ID: 123/9C89 Page 11 of 28 DRA FT Colorado Department of Public Health and Environment _ Air Pollution Control Division 29. Point 015: This source is subject to the requirements of 40 CFR, Part 63, Subpart HH - National Emission Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production Facilities including, but not limited to, the following: • §63.764-General Standards o §63.764 (e)(1) -The owner or operator is exempt from the requirements of paragraph (d) of this section if the criteria listed in paragraph (e)(1)(i) or (ii)of this section are met, except that the records of the determination of these criteria must be maintained as required in§63.774(d)(1). ' ■ §63.764 (e)(1)(ii) — The actual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere are less than 0.90 megagram per year, as determined by the procedures specified in §63.772(b)(2)of this subpart. • §63.772 - Test Methods, Compliance Procedures and Compliance Demonstration o §63.772(b) - Determination of glyco! dehydration unit flowrate or benzene emissions. The procedures of this paragraph shall be used by an owner or operator to determine glycol dehydration unit natural gas flowrate or benzene emissions to meet the criteria for an exemption from control requirements under§63.764(e)(1). ■ §63.772(b)(2) - The determination of actual average benzene emissions from a glycol dehydration unit shall be made using the procedures of either paragraph (b)(2)(i) or (b)(2)(ii) of this section. Emissions shall be determined either uncontrolled, or with federally enforceable controls in place. • §63.772(b)(2)(i) — The owner or operator shall determine actual average benzene emissions using the model GRI- GLYCaIc TM , Version 3.0 or higher, and the procedures presented in the associated GRI-GLYCaIc TM Technical Reference Manual. Inputs to the model shall be representative of actual operating conditions of the glycol dehydration unit and may be determined using the procedures documented in the Gas Research Institute (GRI) report entitled "Atmospheric Rich/Lean Method for Determining Glycol Dehydrator Emissions"(GRI-95/0368.1); or • §63.772(b)(2)(ii) - The owner or operator shall determine an average mass rate of benzene emissions in kilograms per hour through direct measurement using the methods in §63.772(a)(1)(i) or (ii), or an alternative method according to §63.7(f). Annual emissions in kilograms per year shall be determined by multiplying the mass rate by the number of hours the unit is operated per year. This result shall be converted to megagrams per year. • §63.774-Recordkeeping Requirements o §63.774(d)(1) -An owner or operator of a glycol dehydration unit that meets the exemption criteria in §63.764(e)(1)(i) or §63.764(e)(1)(ii) shall maintain AIRS ID: 123/9C89 Page 12 of 28 DRA F T Colorado Department of Public Health and Environment Air Pollution Control Division the records specified in paragraph (d)(1)(i) or paragraph (d)(1)(ii) of this section, as appropriate, for that glycol dehydration unit. ■ §63.774 (d)(1)(ii) - The actual average benzene emissions (in terms of benzene emissions per year) as determined in accordance with §63.772(b)(2). OPERATING 8� MAINTENANCE REQUIREMENTS 30. Points 001, 003, 004, and 012-015: 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.) 31. Points 002: This source is not required to follow a Division-approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Initial Testinq Requirements 32. 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. 33. 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.) 34. 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. 35. 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 AIRS ID: 123/9C89 Page 13 of 28 DRA F T 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. 36. 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 part of the self-certification and used to demonstrate compliance with the emissions factors chosen for this emissions point. 37. 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) 38. Point 015: Within one hundred and eighty days (180)after commencement of operation, the owner or operator shall complete the initial annual extended wet gas analysis testing required by this permit 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.) Periodic Testina Requirements 39. Point 012-013: 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. 40. Point 015: The owner or operator shall complete an extended wet gas analysis prior to the inlet of the TEG dehydrator on an annual basis. Results of the extended wet gas analysis shall be used to calculate emissions of criteria pollutants and hazardous air pollutants per this permit and be provided to the Division upon request. 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 capacity 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. AIRS ID: 123/9C89 Page 14 of 28 DRAFTColorado Department of Public Health and Environment Air Pollution Control Division 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. All previous versions of this permit are cancelled upon issuance of this permit. 45. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. 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. 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 012-014: 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 that the owner or operator is exercising an alternative-operating scenario and is installing a permanent replacement engine. 46. 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 No. 3 Part D). AIRS ID: 12319C89 Page 15 of 28 DRAFTColorado Department of Public Health and Environment Air Pollution Control Division 47. 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 48. 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. 49. 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. 50. 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. 51. 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. 52. 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. 53. 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. AIRS ID: 123/9C89 Page 16 of 28 DRA FT Colorado Department of Public Health and Environment Air Pollution Control Division 54. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Carissa Money Permit Engineer Permit History Issuance Date Description Issuance 3 This Issuance Added new point, AIRS ID 015, for a TEG dehy. Removed points 010 and 011 since source submitted permit application for GP02 June 10, 2015 and requested to remove from facility-wide permit. Issuance 2 April 13, 2015 Issued to Bonanza Creek Energy Operating Company LLC Update to permit limits for points 001 and 004 Cancellation of fugitive equipment leaks (point 005) Cancellation of compressor engines C-1, C-2, C- 3, and C-4(points 006-009) Initial Approval November 17, Issued to Bonanza Creek Energy Operating 2014 Company LLC for equipment at a new compressor station. AIRS ID: 123/9C89 Page 17 of 28 DRAFTColorado 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- a o Main/o2FDocument C/o2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper 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? (lb/yr) Benzene 71432 325 Yes 16 001 n-Hexane 110543 1,818 Yes 91 Toluene 108883 356 Yes 18 Benzene 71432 209 No 209 n-Hexane 110543 3,813 Yes 3,813 002 Toluene 108883 445 Yes 445 Xylenes 1330207 204 No 204 Benzene 71432 180 No 9 n-Hexane 110543 3,099 Yes 155 003 Toluene 108883 139 No 7 Ethylbenzene 100414 21 No 1 Xylenes 1330207 52 Yes 3 Benzene 71432 1,028 Yes 51 n-Hexane 110543 5,676 Yes 284 004 Toluene 108883 1,070 Yes 54 Ethylbenzene 100414 3 No --- Xylenes 1330207 32 No 2 AIRS ID: 12319C89 Page 18 of 28 DRAFTColorado Department of Public Health and Environment Air Pollution Control Division Benzene 71432 29 No 29 Formaldehyde 50000 1,448 Yes 1,448 012 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 1,448 013 Acetaldehyde 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 Benzene 71432 32,604 Yes 1,512 Toluene 108883 30,246 Yes 1,435 015 Ethylbenzene 100414 3,392 Yes 164 Xylenes 1330207 12,279 Yes 600 n-Hexane 110543 9,086 Yes 152 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 1.93 0.01 ProMax n-Hexane 0.0415 0.0021 ProMax Benzene 0.0074 3.7E-04 ProMax Toluene 0.0081 4.05E-04. 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 AIRS ID: 123/9C89 Page 19 of 28 DRAFTColorado Department of Public Health and Environment Air Pollution Control Division Emission Factors-Uncontrolled Pollutant lb/BBL loaded Source VOC 0.32 AP-42 Benzene 0.005 Engineering Estimate n-Hexane 0.09 Engineering Estimate 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/Ib-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 Gas(%) Uncontrolled Controlled Source lb/MMscf Ib/MMscf NOx(lb/MMBTU) 0.068 0.068 AP-42 CO(lb/MMBTU) 0.37 0.37 AP-42 VOC 89.33 121,537.9 6087.149 Gas Analysis Benzene 0.2419 329.131 16.457 Gas Analysis AIRS ID: 123/9C89 Page 20 of 28 DRA F T 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 Toluene 02518 342.691 17.135 Gas Analysis Ethylbenzene 0.0008 1.073 0.054 Gas Analysis Xylenes 0.0079 10.300 0.515 Gas Analysis n-hexane 1.3357 1817.507 90.875 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 012: Pollutant Emission Factors- Emission Factors— Source Uncontrolled Controlled NOx 2.21 Ib/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 Ib/MMBTU AP-42 Acrolein 0.0026 Ib/MMBTU 0.0026 Ib/MMBTU AP-42 Benzene 0.0016 Ib/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. Point 013: Pollutant Emission Factors- Emission Factors— Source Uncontrolled Controlled NOx 2.21 Ib/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 Ib/MMBTU AP-42 Acrolein 0.0026 Ib/MMBTU 0.0026 Ib/MMBTU AP-42 Benzene 0.0016 Ib/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. Point 014: Weight Emission Emission Pollutant Fraction of Factors Factors Source Gas(°/a) Uncontrolled Controlled Ib/MMscf Ib/MMscf NOx ___ 0.068 0.068 AP-42 Ib/MMBTU , CO ___ 0.37 0.37 AP-42 Ib/MMBTU VOC 33.66 2183470 1091.74 Gas Analysis AIRS ID: 123/9C89 Page 21 of 28 I DRA F T 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 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 Point 015: The emission levels contained in this permit are based on information provided in the application and the GRI GlyCalc 4.0 model. 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 012-013: These engines may be subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion E�gines (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.eaa.qov/ttn/atw/area/fr18ia08.pdf 8) Points 012-013: 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 incorporafed 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.eqa.qov/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 9) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of:VOC, CO, Benzene, Toluene, n-Hexane and Total HAPs NANSR Synthetic Minor Source of VOC PSD True Minor Source NSPS Kb Not Applicable NSPS OOOO Not Applicable MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Applicable AIRS ID: 123/9C89 Page 22 of 28 DRA FT Colorado Department of Public Health and Environment Air Pollution Control Division 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.qpoaccess.qov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60,Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 11)A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http:l/www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9C89 Page 23 of 28 DRA F T Colorado Department of Public Heaith 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 A, 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. "Temporar�' is defined as in the same service for 90 operating days or less in any 12 month period. "PermanenY' 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 24 of 28 DRAFTColorado 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 APEN 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: htto://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: 123/9C89 Page 25 of 28 DRAFTColorado Department of Public Health and Environment Air Pollution Control Division For comparison with a short-term limit that is either input based (lb/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 NOx 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 PM,o 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 NOx:The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM�o: Use of natural gas as fuel As defined in 40 CFR Part 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: 12319C89 Page 26 of 28 DRAFTColorado 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 1.0 100<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, § l.B (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 27 of 28 DRAFTColorado 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 28 of 28 � � Bonanza Creek Energy Operating Company,LLC Pronghom 24-7 800ster Slation Permit# 14WE052'I Issuance 3 � AIRS ID 123/9C89/015 , Point Description ' One(1)Triethylene glycol(TEG)natural gas dehydration unit(make,model,senal number.to be detertnined)with a design capacity of 12.0 MMscf per day. This �. emissions unit is equipped with hvo(2)Kimray,model 21015 gas-glycol pumps(one pump serves as a back-up),each with a design capacity of 3.5 gallons per minute. . This unit is equipped vnth a flash tank,reboiler and still vent.Emissions from the still vent are routed to a flare.Emissions from the flash tank are 100%recycled to the � sales gas line o�ro the fuel gas system. Emissions Calculation Review The source used GRI Glycalc 4.0 to estimate emissions.Wet gas composition in the Glycalc run was based on an extended wet gas analyses collected 9/14l20'12 irom a nearby site,44-19 compressor station,which is considered to be representative.Wet gas pressure and temperature are based on expected pressure and temperature for this site.The model was based on the following parameters: Inlet Gas Pressure 800 psig Inlet Gas Temperalure 120 deg F Glycol Recirculate Rate 3.5 gpm `I confrmed with the Kimray pump spec sheet that 3.5 gpm is maximum rate Buffer 0% GRI Glvcalc 4.0 Emissions Resulis Gas throughput 12 MMscfd 372 MMscf/mo� 4,380 MMscf/yr 1095.0 MMscf/quarter STILL VENT Uncontrolled Conirolled Controlled lus BuHer Pollutant Ib/hr Ib/ t Ib/hr Ib/ t Ib/hr Ib/r t %Control VOC 17.716 155192 77.6 0.8858 7760 3.9 0.9 7760 3.9 95% HAPs 8.8184 77249 35.6 0.4409 3862 1.9 0.4 3862 1.9 95% Benzene 3.4525 30,244 15.1 0.1726 1512 0.8 0.2 1512 0.8 95% Toluene 3.2757 28,695 '14.3 0.1638 1435 0.7 0.2 1435 0.7 95% Ethylbenzene 0.3746 3,281 1.6 0.0187 164 0.1 0.0 164 0.1 95% Xylenes '1.3694 11.996 6.0 0.0685 600 0.3 0.1 600 0.3 95% . n-Hexane 0.3459 3,030 1.5 0.0173 152 0.1 0.0 152 0.1 95% 2,2,4Mmeth entane 0.0002 2 0.0 0.0001 1 0.0 0.0 1 0.0 50% FLASH TANK Uncontrolled Controlled Controlled Ws Bufler Pollutant Ib/hr Ibl r t Ib/hr Ib/r t Ib/hr Ib/r t %Control VOC 28.1904 246947.9 123.5 0 0.0 0.0 0.0 0.0 0.0 100% HAPs 1.1831 10364.0 52 0 0.0 0.0 0.0 0.0 0.0 100% Benzene 0.2694 2,360 12 0.0000 0.0 0.0 0.0 0 0.0 100% Toluene 0.1770 1,551 0.8 0.0000 0.0 0.0 0.0 0 0.0 100% Ethylbenzene 0.0126 110 0.1 0.0000 0.0 0.0 0.0 0 0.0 100% Xylenes 0.0323 283 0.1 0.0000 0.0 0.0 0.0 0 0.0 100% n-Hezane 0.6913 6,056 3.0 0 0.0 0.0 0.0 0 0.0 100% 2,2,4tnmeth I entane 0.0005 4 0.0 0 0.0 0.0 0.0 0 0.0 100% TOTAL DEHY EMISSIONS-STILL VENT PLUS FLASH TANK Uncontrolled Cantrolled Controlled lus BuHer Pollutant Qb/hr) Qbtyr) (tpy) QWhr) (Ib/yr) (ipy) (Ib/hr) (IWyr) (tpy) %Control IWMMsc �bl31 day VOC 45.9064 402�40.1 201.1 0.6858 7759.6 3.9 0.9 7759.6 3.9 98% 9'1.81 659 HAPs '10.0015 87613.1 43.8 0.4409 3862.3 1.9 0.4 3862.3 1.9 96% 326 Benzene 3.7279 32,604 16.3 0.1726 15�2.0 0.8 0.2 1512 0.8 95% 7.444 128 Toluene 3.4527 30,246 15.1 0.1638 1434.9 0.7 0.2 1435 0.7 95% 6.905 122 . Ethylbenzene 0.3872 3,392 1.7 0.0187 163.8 0.1 0.0 164 0.1 95% 0.7744 14 Xylenes 1.4017 12,279 6.1 0.0685 600.7 0.3 0.1 600 0.3 95% 2.803 51 n-Hexane 1.0372 9,086 4.5 0.0173 151.5 0.1 0.0 152 0.1 98% 2.0744 13 2,2,4tnmeth I entane 0.0007 6 0.0 0.0001 0.9 0.0 0.0 1 0.0 86% 0.0014 0 Controlled emissions are 6ased on 100%recycle of flash tank and still vent emissions controlled with a combustor. Regulatory Review Reau7ation3.-. .... ... . .. .. ... ... .. .. ._ .. PaR A APEN Requirements APEN is required since uncontrolled actual emissions are greater than 1 tpy VOC. Part B-Construction Permit Requirements Pertnit is re uired since facili -wide uncontrolled actual VOC emissions for all APEN-re uired ints are reater than 2 t Requlation 7—Volatile Omanic Comoounds ...... ... ._ . .._ �� _ . . XII.H VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS Applicant is subject to the emission conirol requirements for glycol dehydrators since it is located in the nonattainment area and uncontmlled actual VOC emissions are greater than'15 tpy XVII.D STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS Per Reg 7,Section XVII.B.5,dehydrators subject to an emission control requirement under 40 CFR Part 63 are ezempt from Section XVII.However,as discussed below in MACT HH,this dehy is not subject to a conirol standard under MACT because it is meeting an emission exemption.Thus,the dehy is still subject to Regulation 7 XVII requirements. Applicant is currently subject to XVIII.D2 because actual uncontrolled VOC emissions are greater than 15 tpy. Applicant is currently subject to XVII.D.3 and XVII.D.4.a because the dehydrator will be constructed after 5/1@015 and uncontrolled actual emissions of VOC are reater than 2 t . ��Reoulatiort 8-'�Con#rW of.HAPs . ,,. .. .. . . . . .. � Part E-MACT HH Since this faciliry is an oil and gas exploration and production facility,it qual�es as a pmduction field facility as defined in MACT HH.As a production field facility,only dehys and storage vessels with flash are inciuded when determining major source status.This production field facility is a synthetic minor source of HAPs and is then an area source of HAPs per MACT HH.This TEG dehy is subject to MACT HH area source requirements.However,the dehy will be able to comply with the exemption by maintaining actual benzene emissions to less than 1984 Ib/yr.This source is only required to calculate and keep records demonstrating that benzene emissions stay . below the exemption threshold. AIRS(County/Plant)123/9C89 Permit No. 14WE0521 Date 5/26/2015 Controlled Controlled Emisison Actual Requested NCRP= Unconirolled Factor Emissions Emissions reportabie Point# SCC Pollutant or CAS Emission Factor Source tp ' tp " PTE tp 'Ctrl.Eff% ? GRI Glycalc VOC 91.81 Ib/MMscf 4.0 3.9 201.1 98.1% Yes GRI Glycalc Benzene 7.4441b/MMscf 4.0 1,512 32,604 95.4% Yes GRI Glycaic 017 31000227 Toluene 6.9051b/MMscf 4.0 1,435 30,246 95.3% Yes GRI Glycalc Eth benzene 0.77441b/MMscf 4.0 164 3,392 952°/, Yes ' GRI Glycalc X lenes 2.803 Ib/MMscf 4.0 600 12,279 95.1% Yes GRI Glycalc n-hexane 2.07441b/MMscf 4A 152 9,086 98.3% Yes Colorado Air Permitting Project Project Details Review Engineer: Carissa Money Package#: 324345 Received Date: 2/5/2015 Review Start Date: 8/11/2015 Section 01-Facility Information Company Name: Bonanza Creek Energy Operating Company,LLC County AIRS ID: 123 Plant AIRS ID: 9C89 Facility Name: Pronghorn 24-7 Booster Station • Physical Address/Location: SESW Sec 7 T5N R61W Type of Facility: Natural Gas Compressor Station Is this facility located in a NAAQS non-attainment area? Yes. If yes,for what pollutant? Ozone(N€lx&VOC) Section 02-Emissions Units In Permit Application Emissions Self Cert AIRS Point# Emissions Source Type Permit# Issuance# Action Engineering Remarks Control? Required? Permit Adding new point to 015 TEG Dehydrator Yes 14WE0521 3 Yes Modification facility-wide permit Section 03-Description of Project Source is requesting to add a new 12.0 MMscf/d TEG dehy at an existing booster station.The dehy will be controlled by 100%recycling of the flash tank emissions and controlling the still vent emissions with a flare.This point will be added as a new point to an existing facility-wide permit. Section 04-Public Comment Requirments Is Public Comment Required? Yes If yes,why? Requesting Synthetic Minor Permit Section 05-Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-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):CO,VOC,HAPs Non-Attainment New Source Review(NANSR):VOC Hazardous Air Pollutants MACT: total HAPs Is this stationary source a major source? No If yes,explain what programs and which pollutants here: � a, w \ � � '" o 0 0q ° -o ¢ � �y O `"' .� .s� SC y o �. o � U g �', wa �' � a a nG abi �' � . � � � '� � ai ° b � � ❑ 0 I C� Q Q C Wf3y b0 N N N N � V � �U A � O P. ~ ❑ ❑❑ 5 ,b 'V � � � � � -4"p v, � � p Q� O N � F. � C7 A y � . � C.-� M c+� cn O in O O >+ �, � � � � a. 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