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Home My WebLink About20142082.tiff STATE OF COLORADO John W.Hickenlooper,Governor Larry Wolk,MD,MSPH OFD.Cozo Executive Director and Chief Medical Officer - FK'/ kdt1.''S Dedicated to protecting and improving the health and environment of the people of Colorado *a rt� 4300 Cherry Creek Dr.S. Laboratory Services Division '/e'/6 Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health www.colorado.gov/cdphe and Environment Weld County -Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 June 20, 2014 Dear Sir or Madam: On June 25, 2014,the Air Pollution Control Division will publish a public notice for Bonanza Creek Energy Operating Company, LLC—Pronghorn 14-11-7HZ, in the Greeley Tribune. 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 date the public notice is published. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health & Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, /7) RECEIVED Clara Gonzales Public Notice Coordinator JUL 10 2014 Stationary Sources COUNTY ons Program WELD Air Pollution Control Division COMMISSIONERS Enclosure Rux 1 .1 cam•. vttr,PA) wcUs Ri w 1- _ -1- 11-14 2014-2082 STATE OF COLORADO John W.Hickenlooper,Governor Larry Wolk,MD,MSPH �P co\re Executive Director and Chief Medical Officer r_17a\S% Dedicated to protecting and improving the health and environment of the people of Colorado . �' 4300 Cherry Creek Dr.S. Laboratory Services Division •fir ren �,�' Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health www.colorado.gov/cdphe and Environment Website Title: Bonanza Creek Energy Operating Company, LLC—Pronghorn 14-11-7HZ—Weld County Released To: Greeley Tribune On: June 20, 2014 Published: June 25, 2014 PUBLIC NOTICE OF A PROPOSED PROJECT OR ACTIVITY WARRANTING PUBLIC COMMENT 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 14-11-7HZ Oil and gas exploration and production facility SWSW S7, T5N, R6I W Weld County The proposed project or activity is as follows: The applicant proposes to install natural gas driven pneumatic pumps for heat trace and water transfer at multiple exploration and production sites. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No.3, Part B, Section III.C.La (25 tpy in a non-attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application,the Division's analysis,and a draft of Construction Permit 12WE2089 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at www.colorado.gov/cdphe/AirPublicNotices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Stuart Siffring Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South,APCD-SS-Bl Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us STATE OF COLORADO 06 C COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 " " . .•1876 • *18.7641 CONSTRUCTION PERMIT PERMIT NO: 1 2 YY E 1 828 Issuance 2 DATE ISSUED: ISSUED TO: Bonanza Creek Energy Operating Company, LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Pronghorn 11-14-5HZ Tank Battery, located in the NWNW of Section 5, Township 5 north, Range 61 west, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Truck Truck loadout of condensate. Emissions from the loadout are Loadout 004 not controlled. Pneumatic One(1) natural gas driven pneumatic pump for heat trace. Pump P-1 012 Sandpiper G1F Serial # 1902013 rated at 600 scf/hr. 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 issuance of this permit, 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/ae/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 issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to AIRS ID: 123/9892 Page 1 of 9 Condensate Loadout TM Version 2012-1 1 Colorado Department of Public Health and Environment Air Pollution Control Division demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, 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 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 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 5. 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 P-1 012 — 391 — Point (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO, VOC CO Emission Type Truck Loadout 004 8.6 Point P-1 007 — 2.3 -- Point See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Annual records of the actual emission rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. During the first twelve (12) months after permit issuance, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months after permit issuance, compliance with only the annual limitation is required. Compliance with the annual limit shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) AIRS ID: 123/9892 Page 2 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division 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. 6. 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 not exceed: • 100 tons per year of any criteria pollutant and/or • 10 tons per year of a single hazardous air pollutant and/or • 25 tons per year of total hazardous air pollutants (HAP). 7. 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 Pollutants Equipment Point Control Device Controlled ID P-1 007 Cimarron Enclosed Flare VOC and HAPs PROCESS LIMITATIONS AND RECORDS 8. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate 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 AIRS Facility Process Parameter Annual Limit Monthly Limit(31 Point Equipment ID days) 004 Truck Loadout Condensate Loading 77,650 BBL 012 P-1 Venting of natural gas 5.3 MMscf/yr 0.45 MMscf/month AIRS ID: 123/9892 Page 3 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months after permit issuance, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months after permit issuance, compliance with only the annual limitation is required. Compliance with the annual throughput limit 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 10. 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) 11. 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.) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 13. 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) OPERATING & MAINTENANCE REQUIREMENTS 14. Point 012: Upon startup of this point, 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.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements • None AIRS ID: 123/9892 Page 4 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division ALTERNATE OPERATING SCENARIOS 15. 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. 16. 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. 17. 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 18. 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 (NOr) in ozone nonattainment areas emitting less than 100 tons of V0C 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. 19. 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 AIRS ID: 123/9892 Page 5 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division 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). GENERAL TERMS AND CONDITIONS: 20. 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. 21. 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. 22. 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. 23. 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. 24. 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 or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. 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: 123/9892 Page 6 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division 26. 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: Stuart Siffring Permit Engineer Permit History Issuance Date Description Issuance 2 This Issuance Add pneumatic pump (012) to permit. Issuance 1 11/20/2012 Issued to Bonanza Creek Energy Operating Company LLC. For the truck loadout of condensate at a new, synthetic minor facility. 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.cd phe.state.co.us/regulations/airreqs/100102agcccommon provisionsreq.pdf. 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 Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(Ib/yr) n-Hexane 110543 C 1204 Yes N/A 004 Benzene 71432 A 261 Yes N/A AIRS ID: 123/9892 Page 7 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division Benzene 71432 A 295.7 Yes 14.8 012 n-Hexane 110543 C 1258.5 Yes 62.9 Toluene 108883 C 296.5 Yes 14.8 5) The emission levels contained in this permit are based on the following emission factors: Point 004: Emission Factors Uncontrolled Source CAS Pollutant Lb/1000 gallons loaded VOC 5.276 AP-42 71432 Benzene 0.0799 Wt.fraction 110543 n-hexane 0.3691 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) = 10.16 psia M (vapor molecular weight) = 36.41 lb/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 vapors by the VOC emission factor. Point 012: Emission Factors Emission Factors AIRS -Uncontrolled -Controlled Point CAS# Pollutant lb/MMscf vented lb/MMscf vented Source VOC 17175.3 _ _ 858.8 All emission factors 108883 Toluene 56.4 2.8 are based on the 110543 n-Hexane 239.4 12.0 displacement 012 equation and the Pronghom 11-14- 71432 Benzene 56.3 2.8 5HZ wet gas analysis. The displacement equation can found in "EPA Emission Inventory Improvement Program Publication:Volume II, Chapter 10-Displacement Equation(10.4-3)." 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status AIRS ID: 123/9892 Page 8 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division Requirement Operating Permit Synthetic Minor Source of: VOC NANSR Synthetic Minor of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End SubpartA—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 9) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: http://www.cdphe.state.co.us/ap/oilqaspermittinq.html AIRS ID: 123/9892 Page 9 of 9 ea 0 • c O 0 0 E N O m N = =• N N y c_ c_ C_ N a C_ 73 y )p {p )p C C (0 U w, Q Q C Z Z Q . C W c C- L in c o N X x O OO • Q a a Z >� 0 O U J J > C J N O J a T c6 I O O a a O o an c U o - 0 o m N C U) a p N = cor N �_ -a cO . - ° n = N co o m N N )O O N C m > ~ N N cp co U CC C '7 O1 N ` 0 i C>/) U (n 0 a) M M O 4 '- CC O 0 000 rl W N L > a n . CO N .c '_ N N W C m aJ Z C N } v CD c (6 O N N C a > N O J N N O) N r y C 0 "T CO C 0) 00 O ≤ninon r CO 0D0 Z rompvoaN ai .. aaj.+ Y O 3L 7t A - aL+ 0 0 O CJ N .-I N 0_ N N X C v a°'i m co z c = c vli N Eta m HLDin tli N E O LLrti E c C ... > .V 'p COZZ a C N N y Z L w ≥ -- N N O C N N Q Q - O u w W w Q a O 2 w C a C N ate+ .. E co p W a o Q d �' .G r 0 CO C a Q i d CJ a r O a) co C U C N O (0 as 0LI LL co 2 < 0 0 Y 0 0 N 0 0 m 0) 0) 1.- } Y _> � -0 \ Y r ` ≥ al VI a -C -0° 3 V 1- N 7. O ♦. N 0 o -O ro CL m o, m E al W L C N J u 0 O -C N u O O n, a, O } C '^ c `i u c E E ., m s > o m = c a E .5 _ j, `m m LO cO n n .m m a CJ Cr ". '° 3 - - o u w .E C 0 v al E °' 0 w @ 'A '5 0 J v lob Si E V- L E 0a O 0 c a) O V— O. °u _ I C cm J '0 m 0. al al al a1 3 w .�^ CO ° • m N N C " c c c 2 a`) a C x u s c a c .9- N '- r3 .C .C .C CO •' r ° E y m y a IL N U y o u u I-- O a-� LL 3 L - 03 ci, — O in. m Z F c o — a tom. 0 0 0 0 0 •N Z o ci `Q J CU y CO a L- 0 E ° a LL �° c o _a w 4-. o -CI `w = `u N N co VI N N N on E co ° a 5 w 2 E in En- o. j a 3 > > > > Z 0 °- o. v C = n r u Cr al a6i cu alw aa) W N 0 C 0 c t E � zacacz � � z v 0c al a) .. a • '4 _ E _ • J co a 3 C N Co CO a 3 O as 0 c C O O w m a o C X X c O O J �. ... = a d a o 0 0 c I U) Q c Cl) Cl) 2 N N J J O L U 0 0 (n Y h0 Q C C J J y C C U STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT Q )-58 AIR POLLUTION CONTROL DIVISION w TELEPHONE: (303)692-3150 `'�a76." CONSTRUCTION PERMIT PERMIT NO: 12WE2081 Issuance 1 DATE ISSUED: ISSUED TO: Bonanza Creek Energy Operating Company LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Pronghorn 31-34-17HZ, located in NWNE Section 17, T5N, R61W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Description Equipment ID Point One (1) Arrow, Model A62, Serial Number SP211-HP3, natural gas-fired, naturally aspirated, 4SRB reciprocating internal combustion engine, site rated at 80 horsepower at El 003 1800 RPM. This engine shall be equipped with a non- selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used to drive a pump at the well head. Truck Loadout 004 Truck loadout of condensate. Emissions from the loadout are not controlled. Pneumatic One(1) natural gas driven pneumatic pump for water Pump P-1 007 transfer. Sandpiper CIF Serial # 1902021 rated at 600 scf/hr. Pneumatic One(1) natural gas driven pneumatic pump for heat trace. Pump P-2 008 Sandpiper G1 F Serial # 1902024 rated at 600 scf/hr. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Arrow A62 engine 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 AIRS ID: 123/9956 Page 1 of 16 NGEngine Version 2012-1 Colorado Department of Public Health and Environment Air Pollution Control Division CONTROL ACT C.R.S. (25-7-101 et see), 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 issuance of this permit, 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 issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, 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 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 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 5. 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) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO VOC CO Emission Type El 003 2.2 — 3.7 Point Truck Loadout 004 -- 5.0 --- Point P-1 007 --- 2.6 --- Point P-2 008 2.6 --- Point See "Notes to Permit Holder for information on emission factors and methods used to calculate limits. 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. AIRS ID: 123/9956 Page 2 of 16 Colorado Department of Public Health and Environment Air Pollution Control Division • 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. 6. 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 Pollutants Equipment Point Control Device Controlled ID El 003 Oxidation catalyst and air/fuel ratio controller NOx and CO P-1 007 Cimarron Enclosed Flare VOC and HAPs P-2 008 Cimarron Enclosed Flare VOC and HAPs PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate 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 Equipment Point Process Parameter Annual Limit ID El 003 Consumption of natural gas as a fuel 6.3 MMscf/yr Truck 004 Throughput of condensate and produced 63,875 bbl/yr Loadout wastewater. P-1 007 Venting of natural gas 5.3 MMscf/yr P-2 008 Venting of natural gas 5.3 MMscf/yr 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 8. 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) 9. 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, AIRS ID: 123/9956 Page 3 of 16 Colorado Department of Public Health and Environment Air Pollution Control Division • Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. &4.) 10. 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.) 11. Point 004: 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) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 13. Points 003, 007, 008: 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.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements No requirements under this section. Periodic Testing Requirements 14. Point 003: This engine is 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. ALTERNATE OPERATING SCENARIOS 15. 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. 16. 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. 17. 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. AIRS ID: 123/9956 Page 4 of 16 Colorado Department of Public Health and Environment • Air Pollution Control Division ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, I I.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 (NO,) 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. 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. 19. 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). 20. MACT Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in AIRS ID: 123/9956 Page 5 of 16 Colorado Department of Public Health and Environment• Air Pollution Control Division ' any permit limitation and shall be subject to all appropriate applicable requirements of that Subpart on the date as stated in the rule as published in the Federal Register. (Reference: Regulation No. 8, Part E) GENERAL TERMS AND CONDITIONS: 21. 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. 22. 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. 23. 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. 24. 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. 25. 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 or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. 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. 27. 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, AIRS ID: 123/9956 Page 6 of 16 • Colorado Department of Public Health and Environment Air Pollution Control Division civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Stuart Siffring Permit Engineer Permit History Issuance Date Description Issuance 2 This Issuance Add pneumatic pumps (007 and 008) to permit. Issuance 1 1/8/2014 Issued to Bonanza Creek Energy Operating Company LLC AIRS ID: 123/9956 Page 7 of 16 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.cdphe.state.co.us/regulations/airreqs/100102aqcccommonprovisionsreq.pdf. 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 Are the Controlled AIRS Pollutant CAS# BIN Emission emissions Emission Rate Point (Ibtyr) reportable? Rate(Ib/yr) Formaldehyde 5000 A 119 Yes 119 Methanol 67561 C 18 No 18 Acetaldehyde 75070 A 16 No 16 003 Acrolein 107028 A 15 No 15 Benzene 71432 A 9 No 9 1,3-Butadiene 106990 A 4 No 4 Toluene 108883 C 3 No 3 n-Hexane 110543 C 637 No N/A Benzene 71432 A 160 Yes N/A 004 Toluene 108883 C 288 No N/A Xylenes 1330207 C 274 No N/A n-Hexane 110543 C 2303 Yes 115 007 Benzene 71432 A 405 Yes 20 n-Hexane 110543 C 2303 Yes 115 008 Benzene 71432 A 405 Yes 20 AIRS ID: 123/9956 Page 8 of 16 • Colorado Department of Public Health and Environment Air Pollution Control Division 5) The emission levels contained in this permit are based on the following emission factors: Point 003: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 4.0510 14.7000 0.7716 2.8000 CO 1.5983 5.8000 1.3228 4.8000 VOC 0.0110 0.0400 0.0110 0.0400 5000 Formaldehyde 0.0205 0.0744 0.0205 0.0744 67561 Methanol 0.0031 0.0111 0.0031 0.0111 75070 Acetaldehyde 0.0028 0.0101 0.0028 0.0101 107028 Acrolein 0.0026 0.0095 0.0026 0.0095 71432 Benzene 0.0016 0.0057 0.0016 0.0057 106990 1,3-Butadiene 0.0007 0.0024 0.0007 0.0024 108883 Toluene 0.0006 0.0020 0.0006 0.0020 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 8000 Btu/hp-hr, a site-rated horsepower value of 80, and a fuel heat value of 918 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Manufacturer CO Manufacturer Manufacturer VOC Manufacturer Manufacturer 5000 Formaldehyde AP-42; Table 3.2-3 (7/2000); Natural AP-42; Table 3.2-3 Gas (7/2000); Natural Gas 67561 Methanol AP-42; Table 3.2-3 (7/2000); Natural No Control Gas 75070 Acetaldehyde AP-42; Table 3.2-3 (7/2000); Natural No Control Gas 107028 Acrolein AP-42; Table 3.2-3 (7/2000); Natural No Control Gas 71432 Benzene AP-42; Table 3.2-3 (7/2000); Natural No Control Gas 106990 1,3-Butadiene AP-42; Table 3.2-3 (7/2000); Natural No Control Gas 108883 Toluene AP-42; Table 3.2-3 (7/2000); Natural No Control Gas Point 004: Emission Factors - Uncontrolled CAS Pollutant lb/BBL loaded Source VOC 0.156 AP-42 71432 Benzene 5.52e-03 See comment below 110543 nHexane 9.95e-03 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) = 6.37 psia AIRS ID: 123/9956 Page 9 of 16 Colorado Department of Public Health and Environment Air Pollution Control Division • M (vapor molecular weight) =40.97 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 vapors by the VOC emission factor. Point 007 and 008: Emission Factors Emission Factors AIRS -Uncontrolled -Controlled Point CAS# Pollutant lb/MMscf vented Ib/MMscf vented Source VOC 20055 1002 All emission factors 110543 n-Hexane 438 22 are based on the 007 displacement and equation and the 008 71432 Benzene 77 4 Pronghorn 31-34- 17HZ wet gas analysis. The displacement equation can found in"EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10-Displacement Equation (10.4-3)." 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN)associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This engine is 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) 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.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: VOC NANSR Synthetic Minor: VOC MACT 7777 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: AIRS ID: 123/9956 Page 10 of 16 • Colorado Department of Public Health and Environment Air Pollution Control Division http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60, Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 11) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: http://www.cdphe.state.co.us/ap/oilciaspermittinghtml AIRS ID: 123/9956 Page 11 of 16 • 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 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. "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: 123/9956 Page 12 of 16 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 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: http://www.colorado.gov/cs/Satellite/CD PH E-AP/C BON/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: 123/9956 Page 13 of 16 Colorado 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 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 NOX: 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 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 subject pp q p ed n Regulation No. 7, section XVI, as specified below: Rich bum 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 bum engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. AIRS ID: 123/9956 Page 14 of 16 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 XVILE—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 X NO 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, § LB (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: 123/9956 Page 15 of 16 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: 123/9956 Page 16 of 16 to E t co E ir. N N O N •c c N w cw 3E cc a r .Ca .@ "N c c @ O o t O Q Q Q z Z < < C 0 C - r C 3 o vi .O w r N x x O rzi Q d a O� O > 0 O OO -I J J J C J N N J a T co E m o a a O U a O) c U o N m o E m = c in O a) I� (O To U -0 c O 4 z a O c‘io 0 v 4 N DI s3 a) a) o ca O) O (h O O _ c c a0, v M m c-'4 co d cc E N ` N U (0 O o co co a fn .CD N N NO a w C t W N L• U O CO - C r M W C c C 01 Z C O �. w > CO co C > r @ > V N J 0 N { N >� ID O) O r N O O > co 0 O O O O in in o r rn o o. ≥ c] d Z coo m Cr 0 a r r o O1 0 a0+ O T T w O E O U_ O .--I N ail; U) x c ea r73 C C C Z Y C N E N (n "_ In N N N O W E O .� O .C N Z O v N N N Z L W w c9 c9 o i (Oj i 2 - C O J O -0 -a c a f0 w w E > d 0 O E C `U' N N a a O u `ti d w Q N =O .r-c-)N w C a 0 C N +T+ .. E W p I C Uo a d ' . e- O (/j c - Q o U I-O c +T' O O) N C i . = CO ;N c N O (a • '> .a a = -`o N C 6 LL CO ¢ a O II / « � $ { 3 } $tn k ] } CU _at k ) 01 CO C “IC0 ) § Ill 4—4-1 el C el ( { t E { E '-a 2 % Ek { 3 - cc § / e ( co CV O in 7k - ( E o2m $ o - co a " ACCCo O- E $ 2z { ( c CO { ai / ) ) ) j \ / ) } k , Ei: 2 § 2 0 « � _ _ _ _ -O f ® Z }- ® Ew ) ( � I ; IIII § OW § ! o ) * ` ! & E « ■ [ 5275 ! � k ) - = 5 ® I ) vEaa ( ) } } } } } / a § I / \ -e z z IX — ea o tE = a § _ w al O % § C >< ^ — C CD CO £k / ) / \ � J c-u L U O O CO U, O CO ;3 °q a @ E Yco c O U • STATE OF COLORADO co Cot.r COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT �i AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 »a7a+ CONSTRUCTION PERMIT PERMIT NO: 12WE2089 Issuance 2 DATE ISSUED: ISSUED TO: Bonanza Creek Operating Company LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Pronghorn 14-11-7HZ, located in SWSW S7 T5N R61W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Description Equipment ID Point Truck Loadout 004 Truck loadout of condensate or produced water. Pneumatic One(1) natural gas driven pneumatic pump for heat trace. Pump P-1 007 Sandpiper G1 F Serial # 1902013 rated at 600 scf/hr. 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, 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 AIRS ID: 123/9960/004 and 007 Page 1 of 10 NGEngine TM Version 2012-1 Colorado Department of Public Health and Environment Air Pollution Control Division 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 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 5. 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 P-1 007 -- 612 -- Point (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Annual Limits: Facility AIRS Tons per Year Emission Type Equipment ID Point NO, VOC CO Truck Loadout 004 -- 5.0 --- Point P-1 007 --- 3.6 -- Point See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Annual records of the actual emission rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. During the first twelve (12) months after permit issuance, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months after permit issuance, 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. AIRS ID: 123/9960/004 and 007 Page 2 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division 6. 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 not exceed: • 100 tons per year of any criteria pollutant and/or • 10 tons per year of a single hazardous air pollutant and/or • 25 tons per year of total hazardous air pollutants (HAP). 7. 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 Pollutants Equipment Point Control Device Controlled ID P-1 007 Cimarron Enclosed Flare VOC and HAPs PROCESS LIMITATIONS AND RECORDS 8. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) 9. This source shall be limited to the following maximum processing rates as listed below. Annual records of the actual processing rate 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 Truck Condensate or Produced Water 004 63,875 BBL/yr Loadout Loading P-1 007 Venting of natural gas 5.3 MMscf/yr 0.45 MMscf/month The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months after permit issuance, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months after permit issuance, compliance with only the annual limitation is required. AIRS ID: 123/9960/004 and 007 Page 3 of 10 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 10. 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) 11. 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.) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 13. 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) OPERATING & MAINTENANCE REQUIREMENTS 14. Point 007: Upon startup of this point, 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.) COMPLIANCE TESTING AND SAMPLING Periodic Testing Requirements None ALTERNATE OPERATING SCENARIOS 15. 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. 16. 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. 17. 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. AIRS ID: 123/9960/004 and 007 Page 4 of 10 • Colorado Department of Public Health and Environment Air Pollution Control Division ADDITIONAL REQUIREMENTS 18. 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 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. 19. 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). GENERAL TERMS AND CONDITIONS: 20. 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. 21. 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 pp 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. AIRS ID: 123/9960/004 and 007 Page 5 of 10 Colorado Department of Public Health and Environment • , Air Pollution Control Division 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. 22. 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. 23. 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. 24. 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 or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. 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. 26. 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: 4th4 Stuart Siffring Permit Engineer Permit History AIRS ID: 123/9960/004 and 007 Page 6 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division Issuance Date Description Issuance 2 This Issuance Add pneumatic pump (007) to permit. Add synthetic minor language to permit. Issuance 1 11/20/2012 Issued to Bonanza Creek Operating Company LLC. Synthetic minor facility. Condensate (001) and Produced water (002) tanks covered under General Permits. AIRS ID: 123/9960/004 and 007 Page 7 of 10 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.cdphe.state.co.us/regulations/airregs/100102agcccommonprovisionsreq.pdf. 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 Are the Controlled AIRS Pollutant CAS# BIN Emission emissions Emission Point Rate reportable? Rate(lb/yr) (Ib/yr) Benzene 71432 A 160 Yes 160 004 n-Hexane 110543 C 637 No 637 Benzene 71432 A 714 Yes 36 007 n-Hexane 110543 C 4092 , Yes 205 Toluene 108883 C 360 Yes 18 5) The emission levels contained in this permit are based on the following emission factors: Point 004: Emission Factors -Uncontrolled CAS Pollutant lb/1000 gal Source VOC 3.72 AP-42 71432 Benzene 0.0594 Engineer Calc. 110543 n-Hexane 0.0237 Engineer Calc. Point 007: Emission Factors Emission Factors AIRS -Uncontrolled -Controlled Point CAS# Pollutant Ib/MMscf vented Ib/MMscf vented Source VOC 27,429.43 1371.5 All emission factors 007 108883 Toluene 68.6 3.4 are based on the 110543 n-Hexane 778.6 38.9 displacement AIRS ID: 123/9960/004 and 007 Page 8 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division Emission Factors Emission Factors AIRS -Uncontrolled -Controlled Point CAS # Pollutant lb/MMscf vented Ib/MMscf vented Source equation and the Pronghorn 31-34- 71432 Benzene 135.8 6.8 6HZ wet gas analysis. The displacement equation can found in "EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10- Displacement Equation (10.4-3)." 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division.A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source PSD or NANSR True Minor Source 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources 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 9) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: http://www.cdphe.state.co.us/ap/oilciaspermitting.html AIRS ID: 123/9960/004 and 007 Page 9 of 10 DRAFT AIRS ID: «AIRS» Page 1 of 10 NGEngine TM Version 2012-1 • C a) E C Ws E C C C C cu as rsb- N Cl.) a) a) •c c a) a) t' a _ C C_ �p -2C a Y N a) a1 O O (J w Q Q Q Z Z < C Lc d - O Ln N (i x x O 76 Q a a u) Z >> O 0 U O J J J _T J To (6 J tE a >. a) E (a o a a° 0 E o) C U o - O) o (6 c Lo a) N 1 'm 0 -c C 0 ' a' a O N U 'CB >>U o N ' t0 O N 03 O1 Y > C O a- F U N CO G J c) M C U C i� 5 O co co a M co U (n O CI M 9 0 0 0 N ri 0 N L CO L o (O N C ocn C O M w = O a u>) - C N- > } �' C ca N N N CO f� r W O > a- Co C 0 0 0 0 in (nor � o o I ≥ m a. UJ o CO v O a r r .Y a) a) a; 4. ? T O w E O a a) e-1 N _a N a) X ._ O a) v co m Z . 4 c ci co E m .1 .1 N mE oc 2 C v o u ii o. °- C Z JO o --o a y Z a CN w w N N C O a ` a a (n G O u `� Cl_ w Tic =o a) N i p c TD. C (n T aU) o N CC - - o in • u < -a Q 0 O O r c (i F 4 o Y_ O O) N C U C N O (6 U U — .o N C a li co 2 < a. U O O cu O O C) O) O) } r r Y >. r r 'a — Y y '^ ai > N r a V I-- N r• H O .O. N LL) N ,a U G. ,_ m a m E C E J d a a m m E U QJ O i L C Y J0.1 -o ` Y Y o a, w Cto LI- 105 _ C C W C a d O a C E O QJ E W Y a OLCD 'in E Y co C >' vi O N j C a O. E C (y0 C QJ a QJ y C y • C C N a w 10 c v w ." n 3 m '.7 oo O c c aQJ E E o to in " o a Co QJ w C E m O In C QJ O• 0 a OU O Y i C inC. C O OVI -. ,„°- N QJ Q) w 3 44 a O t N QJ y M C - on on C c N a C W QU`J — E a c a 'a+• 3sss 3 L- i .. = ,> — E y � w c O1 ✓ vuuur0 .. _ LL a L is m rn Q C E N Z Z F C fA co — -O Y 0 0 0 0 0 = C ca 0 ni a '- � v .. m .. a +a, y E $ a LL LL c a a w u 0 0 v 0 = m CO `w to i to 1.71 1:). E �0 o a 'g C w g E E a a 7 a = = = = 7 = z y .a as QaJ O. c Z Z u 3 a a a a a � c u` .. m ° E N y c CO•• a a 3 a O O m O C a OC a:. m di O x x O 0 O a m y 4) a�i c CO < c CO CO r 0 L UU N 0 CUD d C C J J Y N C O • STATE OF COLORADO �pF'Cp� COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT = AIR POLLUTION CONTROL DIVISION * , * TELEPHONE: (303)692-3150 "rave* CONSTRUCTION PERMIT PERMIT NO: 9 2WE2452 Issuance 2 DATE ISSUED: ISSUED TO: Bonanza Creek Energy Operating Company LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Pronghorn 31-34-15HZ Tank Battery, located in NWNE Sec. 15, T5N, R61W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Description Equipment ID Point One (1) Arrow, Model A-62, Serial Number 6B11D008877, natural gas-fired, naturally aspirated, 4SRB reciprocating internal combustion engine, site rated at 80 horsepower at El 003 1800 RPM. This engine shall be equipped with a non- selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for a pump jack Truck Truck loadout of condensate. Emissions from the loadout Loadout 004 are not controlled. FUG 005 Equipment leaks (fugitive VOCs) from a natural gas exploration and production facility. Pneumatic One(1) natural gas driven pneumatic pump for heat trace. Pump P-1 007 Sandpiper G1 F Serial # 1991638 rated at 600 scf/hr. Point 003: This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Arrow A-62 engine 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 AIRS ID: 123199E0 Page 1 of 18 NGEngine Version 2012-1 Colorado Department of Public Health and Environment Air Pollution Control Division CONTROL ACT C.R.S. (25-7-101 et sea), 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 issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.uslap/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 issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, 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 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 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 5. 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 I I.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO VOC CO Emission Type x El 003 2.2 0.0 • 3.7 Point Truck Loadout 004 0.0 6.4 0.0 Point FUG 005 — 4.4 --- Fugitive P-1 007 -- 2.6 --- Point See "Notes to Permit Holdee'for information on emission factors and methods used to calculate limits. AIRS ID: 123/99E0 Page 2 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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. 6. 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 and liquids analyses, 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. 7. 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 Pollutants Equipment Point Control Device Controlled ID El 003 Non-selective catalytic reduction (NSCR) system NOx and CO and air-fuel ration control.. P-1 007 Cimarron Enclosed Flare VOC and HAPs PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate 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 Equipment Point Process Parameter Annual Limit ID El 003 Consumption of natural gas as a 6.31 fuel MMscf/yr Truck 004 Condensate Loading 58,035 Loadout BBL P-1 007 Venting of natural gas 5.3 MMscf/yr 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 AIRS ID: 123/99E0 Page 3 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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 9. 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) 10. 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.) 11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 12. Point 004: 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) 13. 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. 14. 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 (RACT) for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). This requirement to apply RACT shall be satisfied by installing/implementing the following emission controls: a. Directed Inspection & Maintenance as described below shall satisfy the requirement to apply RACT. i. For leak screening, auditory/visual/olfactory inspection (AVO) will be performed on a semi-annual basis. • ii. For each leak found in the AVO inspection, a gas detector shall be used to determine the size of the leak. The gas detector shall be regularly calibrated. Component leaks greater than 10,000 ppm shall be managed in accordance with Item (vi) below, unless it is unfeasible to make the repair without shutting down the affected operation of the facility. For such component leaks that require a shutdown to be AIRS ID: 123/99E0 Page 4 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division repaired, repair shall occur during the first shutdown of the affected operation after the leak is discovered. Hi. For repair, valves adjacent to the equipment to be repaired will be closed if practicable, minimizing the volume released. iv. Repaired components shall be re-screened to determine if the leak is repaired. v. The following records shall be maintained for a period of two years: • The name of the site screened via AVO inspection and the name of the inspector. • Components evaluated with the gas detector. • Repair methods applied. • Dates of the AVO screenings, gas detector calibrations, attempted repairs, successful repairs, repair delays, and post- repair screenings. vi. Leaks shall be repaired as soon as practicable, but no later than 15 calendar days after detection, unless it is technically or operationally infeasible to make the repair within 15 calendar days. Records documenting the rationale shall be maintained if it is technically or operationally infeasible to make the repair within 15 calendar days. OPERATING & MAINTENANCE REQUIREMENTS 15. Point 003, 007: 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.) 16. Point 004 and 005: This source is not required to follow a Division-approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Periodic Testing Requirements 17. Point 003: This engine is 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. 18. Point 005: On an annual basis, the owner or operator shall complete an extended gas analysis of gas samples and an extended natural gas liquids analysis of liquids that are representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas and liquids analyses shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. AIRS ID: 123199E0 Page 5 of 18 Colorado Department of Public Health and Environment . Air Pollution Control Division ALTERNATE OPERATING SCENARIOS 19. 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. 20. 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. 21. 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 22. 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 (NO ) in ozone nonattainment areas emitting less than 100 tons of V0C 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. Point 003: 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 AIRS ID: 123/99E0 Page 6 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division operator is exercising an alternative-operating scenario and is installing a permanent replacement engine. 23. 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). GENERAL TERMS AND CONDITIONS: 24. 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. 25. 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. 26. 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. 27. 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. 28. 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 or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. AIRS ID: 123199E0 Page 7 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 29. 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. 30. 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: )a r // • Stuart Siffring Permit Engineer Permit History Issuance Date Description Issuance 2 This Issuance Add pneumatic pump (007) to permit. Issuance 1 1/8/2014 Issued to Bonanza Creek Energy Operating Company, LLC AIRS ID: 123199E0 Page 8 of 18 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.cdphe.state.co.us/regulations/airreqs/100102a icccommonprovisionsreq.pdf. 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 Are the Controlled AIRS Pollutant CAS# BIN Emission emissions Emission Point Rate reportable? Rate(Ib/yr) (lb/yr) Formaldehyde 5000 A 119 Yes 119 Methanol 67561 C 18 No 18 Acetaldehyde 75070 A 16 No 16 003 Acrolein 107028 A 15 No 15 Benzene 71432 A 9 No 9 1,3-Butadiene 106990 A 4 No 4 Toluene 108883 C 3 No 3 Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(Ib/yr) n-Hexane 110543 C 900 NO N/A Benzene 71432 A 200 YES N/A 004 Toluene 108883 C 380 NO N/A Ethylbenzene 100414 C 100 NO N/A Xylenes 1330207 C 380 NO N/A AIRS ID: 123/99E0 Page 9 of 18 Colorado Department of Public Health and Environment ' . Air Pollution Control Division Uncontrolled Controlled Emission Are the Emission AIRS Rate emissions Rate Point Pollutant CAS# BIN (Ib/yr) . reportable? (Ib/yr) Benzene 71432 A 72 Yes N/A Toluene 108883 C 130 No N/A 005 Ethylbenzene 100414 C 31 No N/A Xylenes 1330207 C 118 No N/A n-Hexane 110543 C 361 No N/A Benzene 71432 A 405 Yes 20 007 n-Hexane 110543 C 2303 Yes 115 5) The emission levels contained in this permit are based on the following emission factors: Point 003: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 3.9197 14.7000 0.7447 2.7930 CO 1.5465 5.8000 1.2836 4.8140 VOC 0.0107 0.0400 NA NA 71432 Benzene 0.0016 0.0059 NA NA Emission factors are based on a Brake-Specific Fuel Consumption Factor of 8268 Btu/hp-hr, a site-rated horsepower value of 80, and a fuel heat value of 918 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer NSCR CO Manufacturer NSCR VOC Manufacturer No Control 5000 Formaldehyde AP-42; Table 3.2-3 No Control (7/2000); Natural Gas 67561 Methanol AP-42; Table 3.2-3 No Control (7/2000); Natural Gas 75070 Acetaldehyde AP-42; Table 3.2-3 No Control (7/2000); Natural Gas 107028 Acrolein AP-42; Table 3.2-3 No Control (7/2000); Natural Gas 71432 Benzene AP-42; Table 3.2-3 No Control (7/2000); Natural Gas 106990 1,3-Butadiene AP-42; Table 3.2-3 No Control (7/2000); Natural Gas 108883 Toluene AP-42; Table 3.2-3 No Control (7/2000); Natural Gas AIRS ID: 123/99E0 Page 10 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division Point 004: Emission Factors - Uncontrolled CAS Pollutant lb/1000 gal Source loaded VOC 5.28 AP-42 71432 Benzene 0.014987 Eng. Calc 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) = 10.16 psia M (vapor molecular weight) = 36.41 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 vapors by the VOC emission factor. Point 005: Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 494 0 208 153 Flanges 51 0 137 72 Open-ended Lines 29 0 14 5 Pump Seals 0 0 0 0 Valves 83 0 53 28 Other* 15 0 0 2 VOC Content(wt. 0.2928 0.0000 0.9971 1.0000 fraction) Benzene Content(wt. 0.0008 0.0000 0.0150 0.0001 fraction) Toluene Content(wt. 0.0006 0.0000 0.0298 0.0012 fraction) Ethylbenzene(wt. 0.0001 0.0000 0.0071 0.0003 fraction) Xylenes Content(wt. 0.0003 0.0000 0.0280 0.0001 fraction) n-hexane Content(wt. 0.0060 0.0000 0.0692 0.0001 fraction) *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents AIRS ID: 123/99E0 Page 11 of 18 • Colorado Department of Public Health and Environment ' . Air Pollution Control Division TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil Water/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/R95-017 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 and liquids analyses. Point 007: Emission Factors Emission Factors AIRS -Uncontrolled -Controlled Point CAS# Pollutant lb/MMscf vented lb/MMscf vented Source VOC 25069 1253 All emission factors 108883 Toluene 35 ' 1.8 are based on the 110543 n-Hexane 438 21.9 displacement 007 equation and the 71432 Benzene 77 3.8 Pronghorn 31-34- 15HZ wet gas analysis. The displacement equation can found in "EPA Emission Inventory Improvement Program Publication:Volume II, Chapter 10- Displacement Equation (10.4-3)." 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) Point 003: This engine is 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.govlttn/atw/area/fr18ia08.pdf 8) This facility is classified as follows: Applicable Status Requirement AIRS ID: 123/99E0 Page 12 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permit Synthetic Minor/Major Source of: VOC NANSR Synthetic Minor/Major Source of: VOC MACT ZZZZ Area Source Requirements: Not Applicable MACT HH Area Source Requirements: Not Applicable NSPS KKK Not Applicable NSPS OOOO Not Applicable 9) 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 SubpartA—SubpartZ 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 10) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: http://www.cdphe.state.co.us/ap/oilgaspermittinq.html AIRS ID: 123/99E0 Page 13 of 18 • 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 intemal 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. "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: 123/99E0 Page 14 of 18 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 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: http://www.colorado.qov/cs/Satellite/CDPHE-AP/C BO N/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: 123/99E0 Page 15 of 18 Colorado 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 PM10 at any level of emissions and to NOX and 5O2, 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 5O2: Use of natural gas as fuel PM1O: 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 bum engines with a manufacturer's design rate greater than 500 hp shall use a non- selective catalyst and air fuel controller to reduce emission. AIRS ID: 123/99E0 Page 16 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division Lean bum engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. 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, § LB (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 AIRS ID: 123/99E0 Page 17 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart 7777. An analysis of the 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 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: 123199E0 Page 18 of 18 TA a) E g R / co G a) a)ti .c \ 0 / / / f C \ f m $ m c c 03 f 0 < < < Z 0 < C ■ f E 7 M ® o / rj CL 0- / O > O O o -J C% E / C- O E e g as i c \ § o r _ t e / - c O 4 J E 2 w 5 0 2 2 O k N of k = CO LO / S c C•c ° ^ eN E O E co / « n o g 2 © 2 o m = = G q a - / \ _ m q W o o e k / d \ / / » / C O > OOOO1 I 'a A ( e o o T. o T- o m w w $ q o = 0 6 » CO O 2 o c # c I * w � 6 # ■ IP 2 1- a § d t Q G E 6 e k a c § $ # # 2 C - f { 2 E k \ ® 4 ® ® g q § co E c c o O a G 2 o § \ « -c 2 C OE u k $ 2 E \ \ 2 _ 13 c = @ 2 < < \ C ® = 2 c O « "0 $ u 0 0 CO 0 % Z O o0) ca c @ o @ . 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O.o m LL, `o ,n E O .. v v •c v E N m 4 Di 1g 4-1 E !p LL co aa i- .5 c w E E a' n a• > > > a = > z `0 a s aai d o z Z CO mar Cr Cr Cr Cr Cr a C `U +. v) m a, a) a) w a) m m ° c r g z z ac s s ac 0 a) a) , - m -CO E o co _a 3 N y C M CD" a O o co 0 c a 0 y;r C X X O C 0 cli C E Em o C 0 0 bi :c w a w O V ' 0 0 c to a a CO Cl) 4 0 0 L U O O O a To E c C O U t -�-- r• STATE OF COLORADO fQ , 4 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT , c.e>H8 g AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 "_ CONSTRUCTION PERMIT PERMIT NO: 12WE24554 Issuance 2 DATE ISSUED: ISSUED TO: Bonanza Creek Energy Operating Company LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Pronghorn 11-14-12-12HZ Tank Battery, located in NWNW Sec. 12, T5N, R61W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Description Equipment ID Point One (1) Arrow, Model A-62, Serial Number 6B11H015959, natural gas-fired, naturally aspirated, 4SRB reciprocating internal combustion engine, site rated at 80 horsepower at El 003 1800 RPM. This engine shall be equipped with a non- selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for a pump jack Truck Truck loadout of condensate. Emissions from the loadout Loadout 004 are not controlled. FUG 005 Equipment leaks (fugitive VOCs) from a natural gas exploration and production facility. One(1) natural gas driven pneumatic pump for water Pneumatic Pump P-1 006 transfer. Sandpiper G1 F Serial # 19811466 rated at 600 scf/hr. Pneumatic One(1) natural gas driven pneumatic pump for heat trace. Pump P-2 007 Sandpiper G1 F Serial# 19811470 rated at 600 scf/hr. Point 003: This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Arrow A-62 engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. AIRS ID: 123/99E1 Page 1 of 18 NGEngine Version 2012-1 Colorado Department of Public Health and Environment Air Pollution Control Division 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 issuance of this permit, 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 issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, 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 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; (hi) 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 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 5. 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) Annual Limits: Facility AIRS Tons per Year Equipment ID Point Emission Type NO. VOC CO El 003 2.2 0.0 3.7 Point Truck Loadout 004 0.0 6.4 0.0 Point FUG 005 --- 4.4 --- Fugitive AIRS ID: 123/99E1 Page 2 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division P-1 006 --- 2.3 --- Point P-2 007 --- 2.3 --- Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. 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. 6. 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 and liquids analyses, 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. 7. 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 Pollutants Equipment Point Control Device Controlled ID El 003 Non- selective catalytic reduction (NSCR) system NOx and CO and air-fuel ration control.. P-1 006 Cimarron Enclosed Flare VOC and HAPs P-2 007 Cimarron Enclosed Flare VOC and HAPs PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate 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 Equipment Point Process Parameter Annual ii ID El 003 Consumption of natural gas as a fuel 6.31 MMscf/yr Truck 004 Condensate Loading 58,035 BBL Loadout AIRS ID: 123199E1 Page 3 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division P-1 006 Venting of natural gas 5.3 MMscf/yr P-2 007 Venting of natural gas 5.3 MMscf/yr 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 9. Point 003: 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) 10. Point 003 and Point 005: 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.) 11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 12. Point 004: 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) 13. 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. 14. 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 (RACT) for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). This requirement to apply RACT shall be satisfied by installing/implementing the following emission controls: a. Directed Inspection & Maintenance as described below shall satisfy the requirement to apply RACT. AIRS ID: 123/99E1 Page 4 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division i. For leak screening, auditory/visual/olfactory inspection (AVO) will be performed on a semi-annual basis. ii. For each leak found in the AVO inspection, a gas detector shall be used to determine the size of the leak. The gas detector shall be regularly calibrated. Component leaks greater than 10,000 ppm shall be managed in accordance with Item (vi) below, unless it is unfeasible to make the repair without shutting down the affected operation of the facility. For such component leaks that require a shutdown to be repaired, repair shall occur during the first shutdown of the affected operation after the leak is discovered. iii. For repair, valves adjacent to the equipment to be repaired will be closed if practicable, minimizing the volume released. iv. Repaired components shall be re-screened to determine if the leak is repaired. v. The following records shall be maintained for a period of two years: • The name of the site screened via AVO inspection and the name of the inspector. • Components evaluated with the gas detector. • Repair methods applied. • Dates of the AVO screenings, gas detector calibrations, attempted repairs, successful repairs, repair delays, and post- repair screenings. vi. Leaks shall be repaired as soon as practicable, but no later than 15 calendar days after detection, unless it is technically or operationally infeasible to make the repair within 15 calendar days. Records documenting the rationale shall be maintained if it is technically or operationally infeasible to make the repair within 15 calendar days. OPERATING & MAINTENANCE REQUIREMENTS 15. Point 003, 006, 007: 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.) 16. Point 004 and 005: This source is not required to follow a Division-approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Periodic Testing Requirements 17. Point 003: This engine is 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 AIRS ID: 123/99E1 Page 5 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. 18. Point 004: This source is not required to comply with any testing and sampling requirements. 19. Point 005: On an annual basis, the owner or operator shall complete an extended gas analysis of gas samples and an extended natural gas liquids analysis of liquids that are representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP)that may be released as fugitive emissions. This extended gas and liquids analyses shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. ALTERNATE OPERATING SCENARIOS 20. 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. 21. 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. 22. 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 23. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, 'LC) 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 (NO,c) 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. AIRS ID: 123/99E1 Page 6 of 18 Colorado Department of Public Health and Environment Air Pollution Control 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. Point 003: 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. 24. 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). GENERAL TERMS AND CONDITIONS: 25. 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. 26. 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. 27. 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. AIRS ID: 123/99E1 Page 7 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 28. 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. 29. 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 or owner or operator of a source may request a hearing before the AQCC • for review of the Division's action. 30. 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. 31. 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: v /2.;„./ 3;. l 4/9, r n' tit of Stuart Siffring Permit Engineer Permit History Issuance Date Description Issuance 2 This Issuance Add pneumatic pumps (006 and 007)to permit. Issuance 1 1/08/2013 Issued to Bonanza Creek Energy Operating Company, LLC AIRS ID: 123/99E1 Page 8 of 18 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.cd phe.state.co.us/req u lations/airreqs/100102agcccommonprovisionsreq.pdf. 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 Are the Controlled AIRS Pollutant CAS# BIN Emission emissions Emission Point Rate reportable? Rate(Ib/yr) (Ib/yr) Formaldehyde 5000 A 119 Yes 119 Methanol 67561 C 18 No 18 Acetaldehyde 75070 A 16 No 16 003 Acrolein 107028 A 15 No 15 Benzene 71432 A 9 No 9 1,3-Butadiene 106990 A 4 No 4 Toluene 108883 C 3 No 3 Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# BIN (lb/yr) reportable? Rate(Ib/yr) n-Hexane 110543 C 900 NO N/A Benzene 71432 A 200 YES N/A 004 Toluene 108883 C 380 NO N/A Ethylbenzene 100414 C 100 NO N/A Xylenes 1330207 C 380 NO N/A AIRS ID: 123/99E1 Page 9 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division Uncontrolled Controlled Emission Are the Emission AIRS Rate emissions Rate Point Pollutant CAS# BIN (Ib/yr) reportable? (lb/yr) Benzene 71432 A 72 Yes N/A Toluene 108883 C 130 No N/A 005 Ethylbenzene 100414 C 31 No N/A Xylenes 1330207 C 118 No N/A n-Hexane 110543 C 361 No N/A Benzene 71432 A 296 Yes 15 006 Toluene 108883 C 296 No 15 n-Hexane 110543 C 1259 No 63 Benzene 71432 A 296 Yes 15 007 Toluene 108883 C 296 No 15 n-Hexane 110543 C 1259 No 63 5) The emission levels contained in this permit are based on the following emission factors: Point 003: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 3.9197 14.7000 0.7447 2.7930 CO 1.5465 5.8000 1.2836 4.8140 VOC 0.0107 0.0400 NA NA 71432 Benzene 0.0016 0.0059 NA NA Emission factors are based on a Brake-Specific Fuel Consumption Factor of 8268 Btu/hp-hr, a site-rated horsepower value of 80, and a fuel heat value of 918 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer NSCR CO Manufacturer NSCR VOC Manufacturer No Control 5000 Formaldehyde AP-42; Table 3.2-3 No Control (7/2000); Natural Gas 67561 Methanol AP-42; Table 3.2-3 No Control (7/2000); Natural Gas 75070 Acetaldehyde AP-42; Table 3.2-3 No Control (7/2000); Natural Gas 107028 Acrolein AP-42; Table 3.2-3 No Control (7/2000); Natural Gas 71432 Benzene AP-42; Table 3.2-3 No Control (7/2000); Natural Gas 106990 1,3-Butadiene AP-42; Table 3.2-3 No Control AIRS ID: 123/99E1 - Page 10 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division CAS Pollutant Uncontrolled EFSource Controlled EF Source (7/2000); Natural Gas 108883 Toluene AP-42; Table 3.2-3 No Control (7/2000); Natural Gas Point 004: Emission Factors - Uncontrolled CAS Pollutant lb/1000 gal Source loaded VOC 5.28 AP-42 71432 Benzene 0.014987 Eng. Calc 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*MiT S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 10.16 psia M (vapor molecular weight) = 36.41 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 vapors by the VOC emission factor. Point 005: Water/Oil Component Gas Service Heavy Oil Light Oil Service Service Connectors 494 0 208 153 Flanges 51 0 137 72 Open-ended Lines 29 0 14 5 Pump Seals 0 0 0 0 Valves 83 0 53 28 Other* 15 0 0 2 VOC Content(wt. 0.2928 0.0000 0.9971 1.0000 fraction) Benzene Content(wt. 0.0008 0.0000 0.0150 0.0001 fraction) Toluene Content(wt. 0.0006 0.0000 0.0298 0.0012 fraction) Ethylbenzene (wt. 0.0001 0.0000 0.0071 0.0003 fraction) Xylenes Content(wt. 0.0003 0.0000 0.0280 0.0001 fraction) n-hexane Content(wt. 0.0060 0.0000 0.0692 0.000t fraction) • AIRS ID: 123/99E1 Page 11 of 18 Colorado Department of Public Health and Environment • Air Pollution Control Division '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): Component Gas Service Heavy Oil Light Oil Water/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/R95-017 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 and liquids analyses. Point 006 and 007: Emission Factors Emission Factors AIRS -Uncontrolled -Controlled Point CAS# Pollutant lb/MMscf vented Ib/MMscf vented Source VOC 17175 859 All emission factors 108883 Toluene 56 2.8 are based on the 006 110543 n-Hexane 239 12 displacement and equation and the 007 71432 Benzene 56 2.8 Pronghorn 11-14- 12HZ wet gas analysis. The displacement equation can found in "EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10- Displacement Equation (10.4-3)." 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) Point 003: This engine is 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.qov/ttn/atw/area/fr18ia08.pdf 8) This facility is classified as follows: AIRS ID: 123199E1 Page 12 of 18 • Colorado Department of Public Health and Environment Air Pollution Control Division Applicable Status Requirement Operating Permit Synthetic Minor/Major Source of: VOC NANSR Synthetic Minor/Major Source of: VOC MACT ZZZZ Area Source Requirements: Not Applicable MACT HH Area Source Requirements: Not Applicable NSPS KKK Not Applicable • NSPS OOOO Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60, Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 10) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: http://www.cdphe.state.co.us/ap/oileaspermittinghtml AIRS ID: 123199E1 Page 13 of 18 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 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. "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: 123199E1 Page 14 of 18 • 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 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: http://www.co to rado.uov/cs/Satellite/C D PH E-A P/C B O N/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: 123/99E1 Page 15 of 18 Colorado 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 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 NOX: The emission limitations in NSPS JJJJ 3O2: Use of natural gas as fuel PM10: 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. AIRS ID: 123199E? Page 16 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. 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 8, § 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 AIRS ID: 123/99E1 Page 17 of 18 Colorado Department of Public Health and Environment • Air Pollution Control Division A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart 7777. An analysis of the 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 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: 123/99E1 Page 18 of 18 to a) cra t al a) § | ® E c) \ } } \ \ \ [ { < << z z < f / 7 \ °c \ O ] a ) 7 ) § > O g \ \ -J 0 a a 0 \ § / \ ` & = 4442 \ \ Q e ® 4H q \ } \ \ o \ » \ G \ \ \ 2Q \ / - N2 � CD DI \ \ 'Cr) 3c = = r > \ j mm = r r 2 \ } f r j / ± z ) ) ® + ) k ) « aw & aa ) { \ \ y Oe = = m / , � RE22 / | / \ oo — ` / \ ) Z ! ro % 5 / / { ME Ow E � EJ o < _ al 23 7G ® E ) / \ \ \ $ •_ \ o k In es C C � e IN ) § O / 0 kf 0 U- 0 ] < I3 O O N O O a) CO O) } c c >. 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THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Description Equipment ID Point One (1) Arrow, Model A-62, Serial Number 6B11H015818, natural gas-fired, naturally aspirated, 4SRB reciprocating El 003 internal combustion engine, site rated at 80 horsepower at 1800 RPM. This engine shall be equipped with a non- selective catalytic reduction (NSCR) system. This emission unit powers a pump jack. Truck Truck loadout of condensate. Emissions from the loadout Loadout 004 are not controlled. FUG 005 Equipment leaks (fugitive VOCs) from a natural gas exploration and production facility. Pneumatic One(1) natural gas driven pneumatic pump for heat trace. Pump P-1 006 Sandpiper G1 F Serial# 1991658 rated at 600 scf/hr. Point 003: This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Arrow A-62 engine 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: AIRS ID: 123/99E2 Page 1 of 18 NGEngine Version 2012-1 • Colorado Department of Public Health and Environment Air Pollution Control Division REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdohe.state.co.us/ap/downloadforms.htinl. 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 issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, 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 on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (H) 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, I I I.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. 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 6. 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 Equipment ID Point NOx VOC CO P-1 016 --- 612 --- Point (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO VOC CO Emission Type x AIRS ID: 123/99E2 Page 2 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division El 003 2.2 --- 3.7 Point Truck Loadout 004 --- 6.4 --- Point FUG 005 --- 4.43 --- Fugitive P-1 006 --- 3.6 --- Point See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Annual records of the actual emission rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. During the first twelve (12) months after permit issuance, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months after permit issuance, 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. 7. 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 Pollutants Equipment Point Control Device Controlled ID El 003 Non-Selective Catalytic Reduction NOx and CO P-1 006 Cimarron Enclosed Flare VOC and HAPs 8. Point 005: The operator shall calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent extended 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. PROCESS LIMITATIONS AND RECORDS 9. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) • 10. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or AIRS ID: 123199E2 Page 3 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Process Parameter Annual Limit Monthly Limit Equipment ID Point (31 days) El 003 Consumption of natural gas as a 6.30 MMscf/yr fuel Truck 004 Condensate Loadout 58,035 BBL — Loadout P-1 006 Venting of natural gas 5.3 MMscf/yr 0.45 MMscf/month The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months after permit issuance, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months after permit issuance, 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. Points 003,004: 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) 12. 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.) 13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 14. Point 004: 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) 15. 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. AIRS ID: 123199E2 Page 4 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 16. 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 (RACT) for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). This requirement to apply RACT shall be satisfied by installing/implementing the following emission controls: a. Directed Inspection & Maintenance as described below shall satisfy the requirement to apply RACT. i. For leak screening, auditory/visual/olfactory inspection (AVO) will be performed on a semi-annual basis. ii. For each leak found in the AVO inspection, a gas detector shall be used to determine the size of the leak. The gas detector shall be regularly calibrated. Component leaks greater than 10,000 ppm shall be managed in accordance with Item (vi) below, unless it is unfeasible to make the repair without shutting down the affected operation of the facility. For such component leaks that require a shutdown to be repaired, repair shall occur during the first shutdown of the affected operation after the leak is discovered. iii. For repair, valves adjacent to the equipment to be repaired will be closed if practicable, minimizing the volume released. iv. Repaired components shall be re-screened to determine if the leak is repaired. v. The following records shall be maintained for a period of two years: • The name of the site screened via AVO inspection and the name of the inspector. • Components evaluated with the gas detector. • Repair methods applied. • Dates of the AVO screenings, gas detector calibrations, attempted repairs, successful repairs, repair delays, and post- repair screenings. vi. Leaks shall be repaired as soon as practicable, but no later than 15 calendar days after detection, unless it is technically or operationally infeasible to make the repair within 15 calendar days. Records documenting the rationale shall be maintained if it is technically or operationally infeasible to make the repair within 15 calendar days. OPERATING & MAINTENANCE REQUIREMENTS 17. Points 003 and 006: 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.) COMPLIANCE TESTING AND SAMPLING AIRS ID: 123/99E2 Page 5 of 18 • Colorado Department of Public Health and Environment , Air Pollution Control Division Periodic Testing Requirements 18. This engine is 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. 19. Point 005: On an annual basis, the owner or operator shall complete an extended gas analysis of gas samples that is 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. ALTERNATE OPERATING SCENARIOS 20. 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. P tY 21. 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. 22. 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 23. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, 'LC) 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 (NO,) 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. AIRS ID: 123199E2 Page 6 of 18 Colorado Department of Public Health and Environment Air Pollution Control 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. 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. 24. 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). GENERAL TERMS AND CONDITIONS: 25. 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. 26. 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. 27. 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. 28. 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. AIRS ID: 123/99E2 Page 7 of 18 • Colorado Department of Public Health and Environment ' Air Pollution Control Division 29. 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 or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 30. 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. 31. 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. F By: Stuart Siffring Permit Engineer Permit History Issuance Date Description Issuance 3 This Issuance Add pneumatic pump (006) to permit. Issuance 2 1/8/2014 Serial number needed to be changed for engine. Issuance 1 3/6/13 Issued to Bonanza Creek Energy Operating Company LLC AIRS ID: 123/99E2 Page 8 of 18 • 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.cdphe.state.co.us/regulations/a i rregs/100102agcccommonprovisionsreg.pdf. 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 Are the Controlled AIRS Pollutant CAS# BIN Emission emissions Emission Point Rate reportable? Rate(lb/yr) (Ib/yr) Formaldehyde 5000 A 119 Yes N/A Methanol 67561 C 18 No N/A Acetaldehyde 75070 A 16 No N/A 003 Acrolein 107028 A 15 No N/A Benzene 71432 A 9 No N/A 1,3-Butadiene 106990 A 4 No N/A Toluene 108883 C 3 No N/A n-Hexane 110543 C 900 No N/A Benzene 71432 A 200 Yes N/A 004 Toluene 108883 C 380 No N/A Ethylbenzene 100414 C 100 No N/A Xylenes 1330207 C 380 No N/A Benzene 71432 A 72 Yes N/A Toluene 108883 C 130 No N/A 005 Ethylbenzene 100414 C 31 No N/A Xylenes 1330207 C 121 No N/A n-Hexane 110543 C 361 No N/A AIRS ID: 123/99E2 Page 9 of 18 Colorado Department of Public Health and Environment ' , Air Pollution Control Division Benzene 71432 A 713.9 Yes 35.7 006 n-Hexane 110543 C 4092.2 Yes 204.6 Toluene 108883 C 360.3 Yes 18.0 The emission levels contained in this permit are based on the following emission factors: Point 003: Emission Factors- Emission Factors— Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr Ib/MMBtu g/bhp-hr NOx 3.9197 14.7000 0.7447 2.7930 CO 1.5465 5.8000 1.2836 4.8140 VOC 0.0107 0.0400 0.0107 0.0400 5000 Formaldehyde 0.0205 0.0769 0.0205 0.0769 67561 Methanol 0.0031 0.0115 0.0031 0.0115 75070 Acetaldehyde 0.0028 0.0105 0.0028 0.0105 107028 Acrolein 0.0026 0.0099 0.0026 0.0099 71432 Benzene 0.0016 0.0059 0.0016 0.0059 106990 1,3-Butadiene 0.0007 0.0025 0.0007 0.0025 108883 Toluene 0.0006 0.0021 0.0006 0.0021 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 8268 Btu/hp-hr, a site-rated horsepower value of 80, and a fuel heat value of 918 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Manufacturer CO Manufacturer Manufacturer VOC Manufacturer No Control 5000 Formaldehyde AP-42; Table 3.2-3 (7/2000); No Control Natural Gas 67561 Methanol AP-42; Table 3.2-3(7/2000); No Control Natural Gas 75070 Acetaldehyde AP-42; Table 3.2-3 (7/2000); No Control Natural Gas 107028 Acrolein AP-42; Table 3.2-3 (7/2000); No Control Natural Gas 71432 Benzene AP-42; Table 3.2-3 (7/2000); No Control Natural Gas 106990 1,3-Butadiene AP-42; Table 3.2-3 (7/2000); No Control Natural Gas 108883 Toluene AP-42; Table 3.2-3 (7/2000); No Control Natural Gas Point 004: Emission Factors- Uncontrolled CAS Pollutant lb/BBL loaded Source VOC 0.222 AP-42 110543 n-Hexane 0.0154 AP-42 71432 Benzene 0.00333 AP-42 108883 Toluene 0.00662 AP-42 100414 Ethylbenzene 0.00158 AP-42 AIRS ID: 123/99E2 Page 10 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division Emission Factors - Uncontrolled CAS Pollutant lb/BBL loaded Source 1330207 Xylenes 0.00640 AP-42 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) = 10.16 psia M (vapor molecular weight) = 36.41 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 liquids by the VOC emission factor. Point 005: Component Gas Service Heavy Oil Light Oil ervi S Water/Oil Service Connectors 494 0 208 153 Flanges 51 0 137 72 Open-ended Lines 29 0 14 5 Pump Seals 0 0 0 0 Valves 83 0 53 28 Other* 15 0 0 2 VOC Content(wt. 0.2928 1.0000 0.9971 1.0000 fraction) Benzene Content(wt. 0.0008 0.0000 0.0150 0.0001 fraction) Toluene Content(wt. 0.0006 0.0000 0.0298 0.0012 fraction) Ethylbenzene (wt. 0.0001 0.0000 0.0071 0.0003 fraction) Xylenes Content(wt. 0.0003 0.0000 0.0288 0.0001 fraction) n-hexane Content(wt. 0.0060 0.0000 0.0692 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): Component Gas Service Heavy Oil Light Oil ervi S Water/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 AIRS ID: 123/99E2 Page 11 of 18 Colorado Department of Public Health and Environment ' , Air Pollution Control Division Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Source: EPA-453/R95-017 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 and liquids analyses. Point 006: Emission Factors Emission Factors AIRS -Uncontrolled -Controlled Point CAS# Pollutant lb/MMscf vented lb/MMscf vented Source VOC 27467.9 1373.4 All emission factors 108883 Toluene 68.5 3.4 are based on the 110543 n-Hexane 778.6 38.9 displacement 006 equation and the Pronghorn 11-14- 71432 Benzene 135.8 6.8 5HZ wet gas analysis. The displacement equation can found in "EPA Emission Inventory Improvement Program Publication:Volume II, Chapter 10-Displacement Equation (10.4-3)." 5) 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. 6) Point 003: This engine is 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.00v/ttn/atw/area/fr18ia08.pdf 7) Point 003: 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.qov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: htto://www.epa.00vittn/atwiarea/arearules.html 8) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of:VOC NANSR Synthetic Minor Source of:VOC MACT ZZZZ Area Source Requirements:Applicable AIRS ID: 123/99E2 Page 12 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division MACT HH Area Source Requirements: Not Applicable NSPS KKK Not Applicable NSPS OOOO Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60, Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 10) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: http://www.cdphe.state.co.us/ap/oiloaspermittino.html AIRS ID: 123199E2 Page 13 of 18 • 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 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. "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: 123/99E2 Page 14 of 18 • 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 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: http://www.colorado.qov/cs/Satellite/CD PHE-AP/CBO N/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: 123/99E2 Page 15 of 18 Colorado 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 PM10 at any level of emissions and to NOX and 5O2, 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 8O2: Use of natural gas as fuel PM10: 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 bum engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. AIRS ID: 123/99E2 Page 16 of 18 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 1.0 100<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, § 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: 123/99E2 Page 17 of 18 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: 123/99E2 Page 18 of 18 7.6 a) E c m m m 'E c a) c_ E E▪ = a) a) a) a C N a) y c_ c_ C_ N N C_ Y •m @ al C C a) , 0 < < < z z < in• C d C C y C 3 O V• a y 2 2 0 0 00 0 To Q a a fn Z > 0 0 O J J J T C J al Co J d T a) E m O a a° 0 E m c O a cl m N c t laINIE8O a`) 2 m CO r n O CO N O Q M -7 0 () Ota3 w 0 i Z ' N c) O 3 cc) r O co H a) 2 —`- ° 7 (V) LLn cNiy E U UJ0 O) M M W 03' .CN03 O �N+J U 01 Z C L N } O O) > CO a O4 V I�N N O d O O O NO O4 W CO o Ca rn O a ≥ a d Z O W CO O v 0 d r- N- 4.7. _ N N • xt it xt 2 m C U a) .y N O_a N N X - C 03 ea C al cli ea 0 C C 0 [t Z C C N E N N N N E OH E _ _ O co Z U N N y _ w @C iC N a i E U �i a fl- E T U ep J - -O . 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CU C X X O C (j CO C E= k° O c O 0 UC bi �. o- `o v o 0 0 LC UU O O in O no N E J J Y C C C E • STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT 4.0c . AIR POLLUTION CONTROL DIVISION TELEPHONE:(303)692-3150 (an* CONSTRUCTION PERMIT PERMIT NO: 1 2WE245J' 6 Issuance 2 DATE ISSUED: ISSUED TO: Bonanaza Creek Energy Operating Company LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Pronghorn 41-11-9HZ Tank Battery, located in the NENE of Section 9, Township 5N, Range 61W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID One (1)Arrow, Model A-62, Serial Number 6B12A000924, natural El 003 gas-fired, naturally aspirated, 4SRB reciprocating internal combustion engine, site rated at 80 horsepower at 1800 RPM. This engine powers a pump Jack. Truck 004 Truck loadout of Condensate. Loadout FUG 005 Equipment leaks (fugitive VOCs) from a natural gas production facility. Pneumatic One(1) natural gas driven pneumatic pump for water transfer. Pump P-1 008 Sandpiper G1 F Serial # 2040600 rated at 600 scf/hr. Pneumatic 009 One(1) natural gas driven pneumatic pump for heat trace. Pump P-2 Sandpiper G1 F Serial # 2076856 rated at 600 scf/hr. Point 003: This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Arrow A-62 engine 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 AIRS ID: 123/99E3 Page 1 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division 1. YOU MUST notify the Air Pollution Control Division(the Division)no later than fifteen days after issuance of this permit, 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 issuance of this permit,compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions.Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, 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 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; (Hi) 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 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 5. 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) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO voc Emission Type x CO El 003 2.2 --- 3.7 Point Truck Loadout 004 --- 6.4 --- Point Fugitive 005 --- 4.5 --- Point P-1 008 --- 2.9 --- Point P-2 009 --- 2.9 --- Point See "Notes to Permit Holder#4"for information on emission factors and methods used to calculate limits. Compliance with the annual 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 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. 6. 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 AIRS ID: 123/99E3 Page 2 of 11 • Colorado Department of Public Health and Environment Air Pollution Control Division 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. 7. 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 Pollutants Equipment Point Control Device Controlled ID El 003 Non-Selective Catalytic Reduction NOx and CO P-1 008 Cimarron Enclosed Flare VOC and HAPs P-2 009 Cimarron Enclosed Flare VOC and HAPs PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Annual records of the process rates shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point El 003 Consumption of natural gas as a fuel 6.30 MMscf/yr Truck Loadout 004 Condensate and produced water 58,035 BBUyr loading P-1 008 Venting of natural gas 5.3 MMscf/yr P-2 009 Venting of natural gas 5.3 MMscf/yr 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 a The permit number and AIRS ID number shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 10. 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. (Reference: Regulation No. 1, Section II.A.1. &4.) 11. 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.) AIRS ID: 123/99E3 Page 3 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division • 12. These sources are subject to the odor requirements of Regulation No. 2. (State only enforceable) 13. Point 004: 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). 14. 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. 15. Point 005: Synthetic 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(RACT)for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). This requirement to apply RACT shall be satisfied by installing/implementing the following emission controls: a. Directed Inspection&Maintenance as described below shall satisfy the requirement to apply RACT. i. For leak screening, auditory/visual/olfactory inspection (AVO) will be performed on a semi-annual basis. ii. For each leak found in the AVO inspection, a gas detector shall be used to determine the size of the leak. The gas detector shall be regularly calibrated. Component leaks greater than 10,000 ppm shall be managed in accordance with Item (vi) below, unless it is unfeasible to make the repair without shutting down the affected operation of the facility. For such component leaks that require a shutdown to be repaired, repair shall occur during the first shutdown of the affected operation after the leak is discovered. iii. For repair,valves adjacent to the equipment to be repaired will be closed if practicable, minimizing the volume released. iv. Repaired components shall be re-screened to determine if the leak is repaired. v. The following records shall be maintained for a period of two years: • The name of the site screened via AVO inspection and the name of the inspector. • Components evaluated with the gas detector. • Repair methods applied. • Dates of the AVO screenings, gas detector calibrations, attempted repairs, successful repairs, repair delays, and post- repair screenings. vi. Leaks shall be repaired as soon as practicable, but no later than 15 calendar days after detection, unless it is technically or operationally infeasible to make the repair within 15 calendar days. Records AIRS ID: 123/99E3 Page 4 of 11 Colorado Department of Public Health and Environment • Air Pollution Control Division documenting the rationale shall be maintained if it is technically or operationally infeasible to make the repair within 15 calendar days. OPERATING & MAINTENANCE REQUIREMENTS 16. Points 008 and 009: 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.) COMPLIANCE TESTING AND SAMPLING Periodic Testing Requirements 17. 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. ALTERNATE OPERATING SCENARIOS 18. 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. 19. 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. 20. 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 21. A revised Air Pollutant Emission Notice(APEN)shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually 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 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 AIRS ID: 123199E3 Page 5 of 11 Colorado Department of Public Health and Environment . Air Pollution Control Division • 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. 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. 22. 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). GENERAL TERMS AND CONDITIONS 23. 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. 24. 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. 25. This permit is issued in reliance upon the accuracy and completeness of information supplied by the applicant 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 applicant or applicant's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 26. 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. 27. 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 AIRS ID: 123/99E3 Page 6 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division 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 applicant,or the Division revokes a permit,the applicant or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 28. 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. 29. 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: 1Jtr. le Stuart Siffring Permit Engineer Permit History Issuance Date Description Issuance 2 This Issuance Add pneumatic pumps (008 and 009) to permit. Issuance 1 1/8/2014 Issued to Bonanza Creek Energy Operating Company LLC. AIRS ID: 123/99E3 Page 7 of 11 Colorado Department of Public Health and Environment . Air Pollution Control Division > Notes to Permit Holder: 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 permittee 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 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 permittee 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.cdphe.state.co.us/regulations/airreqs/100102agcccommonprovisionsreq.pdf. 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 Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(Ib/yr) Formaldehyde 5000 A 119 Yes 119 Methanol 67561 C 18 No 18 Acetaldehyde 75070 A 16 No 16 003 Acrolein 107028 A 15 No 15 Benzene 71432 A 9 No 9 1,3-Butadiene 106990 A 4 No 4 Benzene 71432 A 192.88 Yes 192.88 Toluene 108883 C 383.83 No 383.83 Ethylbenzene 100414 C 91.88 No 91.88 004 2,2,4- Trimethylpentane 540841 C No Xylenes 1130207 C 370.96 No 370.96 n-Hexane 110543 C 890.88 No 890.88 Benzene 71432 A 80 Yes 80 Toluene 108883 C 120 No 120 005 Ethylbenzene 100414 C 20 No 20 Xylenes 1130207 C 120 No 120 n-Hexane 110543 C 360 No 360 AIRS ID: 123199E3 Page 8 of 11 • Colorado Department of Public Health and Environment • Air Pollution Control Division 008 n-Hexane 110543 C 772 Yes 38.6 009 n-Hexane 110543 C 772 Yes 38.6 5) The emission levels contained in this permit are based on the following emission factors: Point 003: Emission Factors - Emission Factors — Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 3.9197 14.7000 0.7447 2.7930 CO 1.5465 5.8000 1.2836 4.8140 VOC 0.0011 0.0040 0.0011 0.0040 5000 Formaldeh 0.0205 0.0769 0.0205 0.0769 67561 Methanol 0.0031 0.0115 0.0031 0.0115 75070 Acetaldehy 0.0028 0.0105 0.0028 0.0105 107028 Acrolein 0.0026 0.0099 0.0026 0.0099 71432 Benzene 0.0016 0.0059 0.0016 0.0059 106990 1'3 0.0007 0.0025 0.0007 0.0025 Butadiene 108883 Toluene 0.0006 0.0021 0.0006 0.0021 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 8268 Btu/hp-hr, a site-rated horsepower value of 80, and a fuel heat value of 918 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Manufacturer CO Manufacturer Manufacturer VOC Manufacturer No Control 5000 Formaldeh AP42 Tbl 3-2-3 No Control yde 67561 Methanol AP-42; Table 3.2-3 (7/2000); No Control Natural Gas 75070 Acetaldehy AP-42; Table 3.2-3 (7/2000); No Control de Natural Gas 107028 Acrolein AP-42; Table 3.2-3 (7/2000); No Control Natural Gas 71432 Benzene AP-42; Table 3.2-3 (7/2000); No Control Natural Gas 106990 1,3- AP-42; Table 3.2-3 (7/2000); No Control Butadiene Natural Gas 108883 Toluene AP-42; Table 3.2-3 (7/2000); No Control Natural Gas Point 004: I Emission Factors -Uncontrolled AIRS ID: 123/99E3 Page 9 of 11 Colorado Department of Public Health and Environment * . Air Pollution Control Division CAS Pollutant lb/1000 gal Source loaded VOC 5.28 AP42 5.2 eq 1 71432 Benzene 0.08 based on wt% n-Hexane .37 based on wt% The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version 1/95) using the following values: S =0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 10.16 psia M (vapor molecular weight) =36.41 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 vapors by the VOC emission factor. Point 006: Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 494 --- 208 153 Flanges 51 --- 137 72 Open-Ended Lines 29 --- 14 5 Pump Seals -- -- --- — Valves 83 -- 53 28 Other 15 — --- 2 VOC Content(wt%) 29.28% --- 99.71% 100% Benzene Content(wt%) 0.08% 1.5% <0.01% Toluene Content(wt%) 0.06% -- 2.98% a 12% Ethylbenzene(wt%) <0.01% - 0.71% 0.03% Xylenes Content(wt%) 0.03% - 2.88% <0.01% n-hexane Content(wt%) 0.60% - 6.92% <0.01% *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents 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. Point 008 and 009: Emission Factors Emission Factors AIRS -Uncontrolled -Controlled Point CAS# Pollutant lb/MMscf vented lb/MMscf vented Source VOC 22206 1110 All emission factors 108883 Toluene 46 2.3 are based on the 008 110543 n-Hexane 772 38 displacement and equation and the 009 71432 Benzene 55 2.8 Pronghorn 41-11- 9HZ wet gas analysis. The displacement equation can found in "EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10-Displacement Equation (10.4-3)." AIRS ID: 123/99E3 Page 10 of 11 Colorado Department of Public Health and Environment • Air Pollution Control Division 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice(APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at(303)-692- 3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source NANSR Synthetic Minor Source MACT HH Area Source Requirements: Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60,Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 9) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: http://www.cdphe.state.co.us/ap/oilgaspermittinghtml AIRS ID: 123199E3 Page 11 of 11 TA C a) E C al a) N C C E N a) a) a) C C a) al Y C_ C_ N C_ N N C_ Y N @ la C C m Q rO ¢ < < Z Z Q W0d C E 2 _ 3 WI o v r 2 2 O 0 00 0 32 32 Q d a (n Z > U U 0 J O J J > C O N N J IC a T ci E m a 0 o a a 0 E m c U o N C � Eo a) 2 > I.= a O) ` Q _ (O a J O N O Y r O C 0 N Y ll ' Z , - (NI c 7 M LO ` E on U N m M M O5 0 0 0 N w N _C N - - = CO N r c rn r) W c o) W c a) } a c el Z J N O N > W CO r d C O W r C 0 C 0) 0 0 0 0 0 O CO o a) a) N N ≤n in co o) o a ≥ m a z o m v o a r, r- Y Cu N C U N ri N a to U) X — W U) fO CO Z Y Y C C 4 4-I N E N WWII) W V1 N N E O LL E c_ c_ .. .0 'p E 'C o Z v C C) a) a) Z r w m m 0 i E t0 )i a a Z N J O "O -o to a E > + d N C N !0 C Q in O a) u w d W a N 0 ` > - w c a C N Y . 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