HomeMy WebLinkAbout20143032.tiff A CDPHE ' COLORADO
Co ' Department of Public
Health Er Environment
Dedicated to protecting and Improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150 O St
PO Box 758 RECEIVED
Greeley, CO 80632
September 29, 2014 OCT 0 2 2014
WELD COUNTY
COMMISSIONERS
Dear Sir or Madam:
On October 2, 2014, the Air Pollution Control Division will publish a public notice for Bonanza Creek
Energy Operating Company, LLC - State North Platte Central Production Facility 42-26 (COGCC#
434730), in the 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 a Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
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Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303.692.2000 www.colorado.gov/cdphe I a
John W. Hickenlooper, Governor . Larry Wolk,M0,MPH, Executive Director and Chief Medical Officer ,
10-1.0-0 C C' I1 L,TtAL loin 2014-3032
CDPHE Public Notice Of A Proposed Project
CO % ry Or Activity Warranting Public
' Comment
Website Title: Bonanza Creek Energy Operating Company, LLC - State North Platte Central Production
Facility 42-26 (COGCC# 434730) - Weld County
Released To: The Greeley Tribune
On: September 29, 2014
Published: October 2, 2014
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: Bonanza Creek Energy Operating Company, LLC
Facility: State North Platte Central Production Facility 42-26 (COGCC# 434730)
Centralized oil and gas exploration and production site
SENE Section 26, Township 5N, Range 63W, Approximately 7.2 miles east of Kersey
Weld County
The proposed project or activity is as follows: The applicant proposes to operate a natural gas dehydration
unit.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 13WE2819 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Any such comment must be submitted in writing to the following addressee:
Jesse Snyder
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
I V COLORADO
1
kk r STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT acy
AIR POLLUTION CONTROL DIVISION aP
TELEPHONE: (303)692-3150
"1876
CONSTRUCTION PERMIT
PERMIT NO: 1 3WE281 9
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 State North Platte Central Production Facility 42-26
(COGCC#434730), located in the SENE of Section 26, Township 5N, Range 63W, in Weld
County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
One (1) Triethylene glycol (TEG), natural gas dehydration unit
(make, model, serial number are to be determined)with a design
capacity of 12.0 MMscf per day. This emissions unit is equipped
with two (2) Kimray, model 21015, gas-glycol pumps. Each gas-
glycol pump is permitted to operate at the maximum design
capacity, a lean glycol circulation rate of 3.5 gal/min. Only one
Kimray gas-glycol pump will be operated at any given time, the
DEHY-1 001 second gas-glycol pump is used as a back-up only. This gas
dehydration unit is equipped with a flash tank, reboiler and still
vent. Emissions from the still vent are routed to an air-cooled
condenser and then to a combustor with a design destruction
efficiency of at least 98%. Emissions from the flash tank are
routed to a vapor recovery unit (VRU) and recompressed before
being sent to the gas gathering pipeline. Emissions from the flash
tank can alternatively be routed directly to the reboiler fuel system.
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: 123/9BEE/001 Page 1 of 12
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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
https://www.colorado.00v/pacific/cdphe/other-air-permittinq-notices. 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 (180) days after commencement of operation, compliance
with the conditions contained in this permit, with the exception of condition 24, shall be
demonstrated to the Division. The owner or operator shall demonstrate compliance with
condition 24 to the Division within two hundred and seventy(270)days after commencement
of operation. It is the owner or operator's responsibility to self-certify compliance with the
conditions. Failure to demonstrate compliance within 180 days, or within 270 days for
condition 24, may result in revocation of the permit. (Reference: Regulation No. 3, Part B,
III.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 fora period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline per
Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self-certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. The following information shall be provided to the Division within fifteen (15) days after
commencement of operation.
• manufacturer
• model number
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III.E.)
6. 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
7. 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)
AIRS ID: 123/9BEE/001 Page 2 of 12
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Air Pollution Control Division
Monthly Limits:
Facility AIRS Pounds per Month
Emission Type
Equipment ID Point NO, VOC CO
DEHY-1 001 356.8 --- Point
Monthly emission limits are expressed to the nearest tenth>APEN requested limits. Note: Monthly
emission limits are based on a 31-day month.
The owner or operator shall calculate monthly emissions based on the calendar month.
Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359
lb/month.
Facility-wide emissions of total hazardous air pollutants shall be less than 3,398 lb/month.
Annual Limits:
Facility AIRS Tons per Year
Emission Type
Equipment ID Point NO, VOC CO
DEHY-1 001 --- 2.1 --- Point
See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Annual emission limits are expressed to the nearest tenth >APEN requested limits.
Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy.
Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
During the first twelve (12) months of operation, compliance with both the monthly and
annual emission limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from
each emission unit, on a rolling twelve (12) month total. By the end of each month a new
twelve-month total shall be calculated based on the previous twelve months' data. The
permit holder shall calculate emissions each month and keep a compliance record on site or
at a local field office with site responsibility, for Division review. This rolling twelve-month
total shall apply to all permitted emission units, requiring an APEN, at this facility.
8. Compliance with the emission limits in this permit shall be demonstrated by running the GRI
GlyCalc model version 4.0 or higher on a monthly basis using the most recent wet gas
analysis and recorded operational values(including gas throughput, lean glycol recirculation
rate, VRU downtime and other operational values specified in the O&M Plan). Recorded
operational values, except for gas throughput,shall be averaged on a monthly basis for input
into GRI GlyCalc and be provided to the Division upon request.
9. 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.)
AIRS ID: 123/9BEE/001 Page 3 of 12
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Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
Flash gas recompression using a vapor recovery unit or
DENY-1 001 combustion of flash gas in the reboiler fuel system. Air- VOC and
cooled condenser for reboiler still vent with effluent HAPs
vapors routed to an enclosed combustor.
10. 100% of emissions that result from the flash tank associated with this dehydrator shall be
recycled. The source shall route flash gas emissions to a vapor recovery unit(VRU)to be
recompressed before being sent to the gas gathering pipeline. Emissions from the flash
tank can alternatively be routed directly to the reboiler fuel system for combustion.
PROCESS LIMITATIONS AND RECORDS
11. 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 Annual Monthly Limit
Equipment Point Process Parameter Limit (31 days)
ID
DEHY-1 001 Natural gas throughput 4,380 372
MMscf/yr MMscf/month
The owner or operator shall calculate monthly process rates based on the calendar month.
During the first twelve (12) months of operation, compliance with both the monthly and
annual throughput limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required. •
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months'data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility,for Division
review.
12. This unit shall be limited to the maximum lean glycol circulation rate of 3.5 gallons per
minute. The lean glycol recirculation rate shall be recorded daily in a log maintained on site
and made available to the Division for inspection upon request. (Reference: Regulation No.
3, Part B, II.A.4)
Note: The source has voluntarily elected to monitor glycol recirculation rate more frequently than
required by Division standard Operating and Maintenance policy. See "Notes to Permit Holder"for
more information on the requested monitoring frequency.
STATE AND FEDERAL REGULATORY REQUIREMENTS
13. 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)
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Co Azdo p e o Public Health and Environment
Air Pollution Control Division
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14. 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.)
15. This source is subject to the odor requirements of Regulation No.2. (State only enforceable)
16. This equipment is subject to the control requirements for glycol natural gas dehydrators
under Regulation No. 7, Section XII.H. Beginning May 1, 2005, uncontrolled actual
emissions of volatile organic compounds from the still vent and vent from any gas-
condensate-glycol (GCG) separator (flash separator or flash tank), if present, shall be
reduced by at least 90 percent through the use of air pollution control equipment.
This source shall comply with all applicable general provisions of Regulation 7, Section XII.
17. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General
Provisions (State only enforceable). If a flare or other combustion device is used to control
emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed,
have no visible emissions during normal operations, and be designed so that an observer
can, by means of visual observation from the outside of the enclosed flare or combustion
device, or by other convenient means approved by the Division, determine whether it is
operating properly. The operator shall comply with all applicable requirements of Section
XVII.
18. This equipment is subject to the control requirements for glycol natural gas dehydrators
under Regulation No. 7, Section XVII.D (State only enforceable). Beginning May 1, 2008,
uncontrolled actual emissions of volatile organic compounds from the still vent and vent from
any gas-condensate-glycol (GCG)separator(flash separator or flash tank), if present, shall
be reduced by an average of at least 90 percent through the use of air pollution control
equipment.
This source shall comply with all applicable general provisions of Regulation 7,Section XVII.
19. This source is subject to the requirements of 40 CFR, Part 63, Subpart HH - National
Emission Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural
Gas Production Facilities including, but not limited to, the following:
• §63.764 - General Standards
o §63.764 (e)(1) -The owner or operator is exempt from the requirements of
paragraph (d)of this section if the criteria listed in paragraph (e)(1)(i)or(ii)of this
section are met, except that the records of the determination of these criteria
must be maintained as required in §63.774(d)(1).
• §63.764 (e)(1)(ii)—The actual average emissions of benzene from the
glycol dehydration unit process vent to the atmosphere are less than 0.90
megagram per year, as determined by the procedures specified in
§63.772(b)(2) of this subpart.
AIRS ID: 123/9BEE/001 Page 5 of 12
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• §63.772-Test Methods,Compliance Procedures and Compliance Demonstration
o §63.772(b) - Determination of glycol dehydration unit flowrate or benzene
emissions. The procedures of this paragraph shall be used by an owner or
operator to determine glycol dehydration unit natural gas flowrate or benzene
emissions to meet the criteria for an exemption from control requirements under
§63.764(e)(1).
• §63.772(b)(1) -The determination of actual flowrate of natural gas to a
glycol dehydration unit shall be made using the procedures of either
paragraph (b)(1)(i) or(b)(1)(ii) of this section.
• §63.772(b)(1)(i)—The owner or operator shall install and operate
a monitoring instrument that directly measures natural gas
flowrate to the glycol dehydration unit with an accuracy of plus or
minus 2 percent or better. The owner or operator shall convert
annual natural gas flowrate to a daily average by dividing the
annual flowrate by the number of days per year the glycol
dehydration unit processed natural gas.
• §63.772(b)(1)(ii) -The owner or operator shall document, to the
Administrator's satisfaction, that the actual annual average
natural gas flowrate to the glycol dehydration unit is less than 85
thousand standard cubic meters per day.
• §63.772(b)(2)-The determination of actual average benzene emissions
from a glycol dehydration unit shall be made using the procedures of
either paragraph (b)(2)(i) or (b)(2)(ii) of this section. Emissions shall be
determined either uncontrolled, or with federally enforceable controls in
place.
• §63.772(b)(2)(i)—The owner or operator shall determine actual
average benzene emissions using the model GRI-GLYCaIc TM
Version 3.0 or higher, and the procedures presented in the
associated GRI-GLYCaIc'Technical Reference Manual. Inputs
to the model shall be representative of actual operating
conditions of the glycol dehydration unit and may be determined
using the procedures documented in the Gas Research Institute
(GRI) report entitled "Atmospheric Rich/Lean Method for
Determining Glycol Dehydrator Emissions" (GRI-95/0368.1); or
• §63.772(b)(2)(ii) - The owner or operator shall determine an
average mass rate of benzene emissions in kilograms per hour
through direct measurement using the methods in
§63.772(a)(1)(i) or (U), or an alternative method according to
§63.7(f). Annual emissions in kilograms per year shall be
determined by multiplying the mass rate by the number of hours
the unit is operated per year. This result shall be converted to
megagrams per year.
• §63.774 - Recordkeeping Requirements
o §63.774(d)(1)-An owner or operator of a glycol dehydration unit that meets the
exemption criteria in §63.764(e)(1)(i) or §63.764(e)(1)(ii) shall maintain the
AIRS ID: 123/9BEE/001 Page 6 of 12
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records specified inparagraph(d)(1)(i) or paragraph (d)(1)(ii) of this section, as
appropriate, for that glycol dehydration unit.
• §63.774(d)(1)(i)—The actual annual average natural gas throughput(in
terms of natural gas flowrate to the glycol dehydration unit per day) as
determined in accordance with §63.772(b)(1), or
• §63.774 (d)(1)(ii) -The actual average benzene emissions (in terms of
benzene emissions per year) as determined in accordance with
§63.772(b)(2).
OPERATING & MAINTENANCE REQUIREMENTS
20. 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.)
21. The condenser outlet temperature shall be recorded as per the frequency required in the
approved O&M Plan. This information shall be maintained in a log on site and made
available to the Division for inspection upon request. The condenser outlet temperature
shall not exceed 160 °F on a monthly average basis.
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
22. Within one hundred and eighty(180) days after commencement of operation, the owner or
operator shall demonstrate compliance with opacity standards, using EPA Method 22 to
determine the presence or absence of visible emissions. "Visible Emissions" means
observations of smoke for any period or periods of duration greater than or equal to one(1)
minute in any fifteen (15) minute period during normal operation. (Reference: Regulation No.
7, Section XVII.A.II)
23. Within one hundred and eighty(180) days after commencement of operation,the owner or
operator shall complete the initial annual extended wet gas analysis testing required by this
permit and submit the results to the Division as part of the self-certification process to ensure
compliance with emissions limits. (Reference: Regulation No. 3, Part B, Section III.E.)
24. A source initial compliance test on AIRS emissions point 001 shall be conducted within two
hundred and seventy(270)days after commencement of operation to measure the emission
rate(s)for the pollutants listed below in order to demonstrate compliance with the emission
limits contained in this permit.
Volatile Organic Compounds using EPA approved methods.
The operator shall measure and record, using EPA approved methods, the VOC mass
emission rate at the outlet of the enclosed combustor used to control air-cooled condenser
emissions to demonstrate compliance with the emission limits contained in this permit. For
the purpose of this test, process models shall not be used to determine the mass flow rate or
composition of the enclosed combustion device being tested.The dehydration unit must be
operating at the lean glycol circulation rate capacity as stated in this permit plus or minus
10% for the duration of the test. The condenser outlet temperature shall be 160°F plus or
minus 10% for the duration of the test. The natural gas throughput, lean glycol circulation
rate, condenser outlet temperature, and flash tank temperature and pressure shall be
monitored and recorded during this test.
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1■�_ Air Pollution Control Division
The test protocol must be in accordance with the requirements of the Air Pollution Control
Division Compliance Test Manual and shall be submitted to the Division for review and
approval at least thirty (30) days prior to testing. No compliance test shall be conducted
without prior approval from the Division.Any compliance test conducted to show compliance
with a monthly or annual emission limitation shall have the results projected up to the
monthly or annual averaging time by multiplying the test results by the allowable number of
operating hours for that averaging time (Reference: Regulation No. 3, Part B., Section
III.G.3)
Periodic Testing Requirements
25. The owner or operator shall complete an extended wet gas analysis prior to the inlet of the
TEG dehydrator on an annual basis. Results of the wet gas analysis shall be used to
calculate emissions of criteria pollutants and hazardous air pollutants per this permit and be
provided to the Division upon request.
ADDITIONAL REQUIREMENTS
26. 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(NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO, per year, a
change in annual actual emissions of one (1) ton per year or more or five percent,
whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of
five percent or 50 tons per year or more,whichever is less, above the level reported
on the last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5)tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
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.
27. 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).
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Air Pollution Control Division
28. MACT Subpart HH -National Emission Standards for Hazardous Air Pollutants From Oil and
Natural Gas Production Facilities major stationary source requirements shall apply to this
stationary source at any such time that this stationary source becomes major solely by virtue
of a relaxation in any permit limitation and shall be subject to all appropriate applicable
requirements of Subpart HH. (Reference: Regulation No. 8, Part E)
GENERAL TERMS AND CONDITIONS
29. 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.
30. 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.
31. 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.
32. 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.
33. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence,this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
34. 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.
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p Public Health and Environment
Air Pollution Control Division
35. 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: DRAFT
Jesse Snyder
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Bonanza Creek Energy Operating
Company LLC
This permit issuance includes the addition of
one (1) 12.0 MMscf/day TEG natural gas
dehydration unit. At the time of permit
application make, model, and S/N were not
available for the TEG Dehy. Permit application
was submitted concurrently with application for
twelve (12) RICE (AIRS Points 002-013)
permitted under construction permit#
13WE2994: two (2) lean burn gas lift engines,
three (3) rich burn generator engines, and seven
(7) rich burn VRU compressor engines
collocated with AIRS Point 001.
A subsequent permit modification received by
the Division (5/27/2014) includes the addition of
twenty-three (23) proposed new AIRS emission
points (AIRS Points 014-036) including: one
(1) condensate tank battery, one (1) produced
water tank battery, (1) emergency gas flare,
fifteen (15) high/low pressure separators, three
(3) vapor recovery towers, one (1)fugitive
component equipment leaks, and one (1)
hydrocarbon liquid loading activity. This permit
modification also proposes revisions to seven
(7) existing permitted RICE, AIRS Points 007 -
013.
AIRS ID: 123/9BEE/001 Page 10 of 12
inCo do p e o Public PollutionHealth Controland DivisionEnvironment
h.
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit.An invoice for these fees
will be issued after the permit is issued.The permit holder shall pay the invoice within 30 days of receipt of
the invoice. Failure to pay the invoice will result in revocation of this permit(Reference: Regulation No. 3,
Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are based on
the consumption rates requested in the permit application. These limits may be revised upon request of
the owner or operator providing there is no exceedance of any specific emission control regulation or any
ambient air quality standard. A revised air pollution emission notice (APEN) and complete application
form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions.The owner or operator shall notify the Division of any
malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon
as possible, but no later than noon of the next working day, followed by written notice to the Division
addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See:
http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE-
Main%2FDocument C%2FCBONAddLtnkView&cid=125159938964184oaciename=CBONWrapper
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
Uncontrolled
Emission Are the Controlled
AIRS Rate emissions Emission
Point Pollutant CAS# BIN (lb/yr) reportable? Rate(Ib/yr)
Benzene 71432 A 16,248.0 Yes 712.2
Toluene 108883 C 16,100.0 Yes 664.9
001 Ethylbenzene 100414 C 1,825.6 Yes 66.6
Xylenes 1330207 C 9,606.2 Yes 338.1
Hexane 110543 C 5,032.6 Yes 81.5
5) The emission levels contained in this permit are based on information provided in the application and
the GRI GlyCalc 4.0 model. The source assumed the inlet gas temperature of 120.0°F and pressure
of 800.0 psig. The permitted lean glycol recirculation rate is 3.5 gallons per minute. The source
specified flash tank operation at a temperature of 150.0°F and a pressure of 125.0 psig, with 100%
recompression/recycle of flash gas emissions. Still vent vapors are routed to an air-cooled
condenser permitted at a maximum outlet temperature of 160.0°F at a pressure of 12.4 psia.
Condenser emissions are controlled by an enclosed combustor. The enclosed combustor is granted
a 95% reduction for the control of uncondensed vapors. Emission factors are based on the sum of
flash tank and still vent emissions from a GlyCalc report. Controlled emissions are based on 100%
recompression/recycle of the flash tank emissions and a 95% control of vapors from the condenser
effluent stream.
AIRS ID: 123/9BEE/001 Page 11 of 12
Co do p e o Public Health and Environment
Air Pollution Control Division
6) The source has voluntarily elected to monitor glycol recirculation rate daily such that this permit will be
in compliance with the monitoring frequency outlined in the Division approved O&M plan once
emissions from proposed equipment,AIRS Points 014—036, are installed (see above permit history
for a description of proposed equipment to be installed). At the time of this permitting action,
permitted facility emissions are less than 80 TPY VOC and glycol recirculation rate should be
recorded weekly. However, subsequent to permitting of the proposed AIRS Points 014-036, overall
permitted facility emissions are projected to exceed 80 TPY VOC, requiring glycol recirculation rate to
be monitored daily.
7) 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.
8) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor of: NOx, CO, VOC, HAPs (HCHO)
NANSR Synthetic Minor of: NOx, CO, VOC, HAPs (HCHO)
PSD Synthetic Minor of: CO
MACT HH Area Source Requirements: Applicable
NSPS KKK 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 7777—Subpart MMMMM
MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX
10) A self certification form and guidance on how to self-certify compliance as required by this permit may
be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification
AIRS ID: 123/9BEE/001 Page 12 of 12
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name: Bonanza Creek Energy Operating Company
Permit Number: 13WE2819
Source Location: State North Platte Central Production Facility 42-26 (COGCC#434730)
SENE Section 26, Township 5N, Range 63W
Equipment Description: 12.0 MMscf/day Natural Gas Dehydration Unit
AIRS ID: 123/9BEE/001
Date: 7/28/2014
Review Engineer Jesse Snyder
Control Engineer: Stefanie Rucker
Section 2—Action Completed
Grandfathered Modification APEN Required/Permit Exempt
X CP1 Transfer of Ownership APEN Exempt/Permit Exempt
Section 3—Applicant Completeness Review
Was the correct APEN submitted for this source type? X Yes No
Is the APEN signed with an original signature? X Yes No
Was the APEN filled out completely? X Yes No
Did the applicant submit all required paperwork? Yes X No
Did the applicant provide ample information to determine emission rates? Yes X No
If you answered "no"to any Several information requests were made by the Division to the consultant
of the above, when did you and operator throughout the permitting process.
mail an Information Request
letter to the source? On 5/20/2014 the permit application was put on hold at the request of the
consultant in order to collect design specifications from the operator.
On 7/14/2014 a revised permit application, APEN and GLYCalc model
were received by the Division.
On 7/29/2014 a redlined APEN correcting previously submitted emissions
was provided to the Division. In addition, updated GLYCalc model results
and supporting representative gas analyses were provided to the Division.
On 8/6/2014 a redlined APEN correcting previously submitted emissions
was provided to the Division. In addition, updated GLYCaIc model results
were provided to the Division to address a discrepancy with benzene
emissions.
On 8/13/2014 a revised O&M plan and documentation confirming the
combustor design destruction efficiency were provided to the Division.
On what date was this
application complete? August 13, 2014
Page 1
Section 4—Source Description
AIRS Point Equipment Description
One(1)Triethylene glycol (TEG), natural gas dehydration unit(make, model, serial
number are to be determined)with a design capacity of 12.0 MMscf per day. This
emissions unit is equipped with two(2) Kimray, model 21015, gas-glycol pumps. Each
gas-glycol pump is permitted to operate at the maximum design capacity, a lean glycol
circulation rate of 3.5 gaVmin. Only one Kimray gas-glycol pump will be operated at any
001 given time, the second gas-glycol pump is used as a back-up only. This gas dehydration
unit is equipped with a flash tank, reboiler and still vent: Emissions from the still vent are
routed to an air-cooled condenser and then to a combustor with a design destruction
efficiency of at least 98%. Emissions from the flash tank are routed to a vapor recovery
unit(VRU) and recompressed before being sent to the gas gathering pipeline. Emissions
from the flash tank can alternatively be routed directly to the reboiler fuel system.
Is this a portable source? Yes X No
Is this location in a non-attainment area for any criteria X Yes No
pollutant?
If"yes", for what pollutant? PM1c CO X Ozone
Is this location in an attainment maintenance area for Yes X No
any criteria pollutant?
If"yes", for what pollutant?
(Note: These pollutants are subject to minor source PM,() CO Ozone
RACT per Regulation 3, Part B, Section III.D.2)
Is this source located in the 8-hour ozone non-
attainment region? (Note: If"yes"the provisions of X Yes No
Regulation 7, Sections XII and XVII.C may apply)
Section 5—Emission Estimate Information
AIRS Point Emission Factor Source
001 GRI Gly-Calc v4.0(Refer to Section 14 for calculations)
Did the applicant provide actual process data for the emission inventory? Yes X No
Basis for Potential to Emit(PTEI
AIRS Point Process Consumption/Throughput/Production
001 4,380 MMSCF per year, 3.5 gallons per minute glycol circulation rate
Basis for Permitted Emissions(Permit Limits)
AIRS Point Process Consumption/Throughput/Production
001 4,380 MMSCF per year,3.5 gallons per minute glycol circulation rate
Does this source use a control device? X Yes No
% Reduction
AIRS Point Process Control Device Description
Granted
Flash Gas Recompression and Recycle 100.0
Still Vent Condenser(maximum outlet temp. = 160°F) 18.9
001 et Still Vent Enclosed Combustor 95.0
Still Vent Condenser and Enclosed Combustor Combined 98.7
Destruction Efficiency
Page 2
Section 6—Emission Summary (tons per year)
Point NO, VOC CO Single HAP Total HAP
PTE Before Emissions 001 0.1 161.0 0.4 8.1 (Benzene) 24.4
Controls/Limits:
002 6.1 16.8 37.7 4.4 (Formaldehyde) 5.2
003 6.1 16.8 37.7 4.4 (Formaldehyde) 5.2
004 40.6 1.01 40.6 0.6 (Formaldehyde) 0.7
005 40.6 1.01 40.6 0.6 (Formaldehyde) 0.7
006 40.6 1.01 40.6 0.6 (Formaldehyde) 0.7
007 9.9 0.8 16.6 0.1 (Formaldehyde) 0.2
008 9.9 0.8 16.6 0.1 (Formaldehyde) 0.2
009 9.9 0.8 16.6 0.1 (Formaldehyde) 0.2
010 9.9 0.8 16.6 0.1 (Formaldehyde) 0.2
011 9.9 0.8 16.6 0.1 (Formaldehyde) 0.2
012 9.9 0.8 16.6 0.1 (Formaldehyde) 0.2
013 9.9 0.8 16.6 0.1 (Formaldehyde) 0.2
Facota
ity
T lit 203.4 203.2 313.8 11.3(Formaldehyde) 38.3
Total
Controlled point 001 0.1 2.1 0.4 0.4 (Benzene) 0.9
source emission rate:
002 6.1 2.3 12.1 2.2 (Formaldehyde) 3.0
•
003 6.1 2.3 12.1 2.2 (Formaldehyde) 3.0
004 2.3 1.0 4.7 0.6 (Formaldehyde) 0.7
005 2.3 1.0 4.7 0.6 (Formaldehyde) 0.7
006 2.3 1.0 4.7 0.6 (Formaldehyde) 0.7
007 1.2 0.8 2.3 0.1 (Formaldehyde) 0.2
008 1.2 0.8 2.3 0.1 (Formaldehyde) 0.2
009 1.2 0.8 2.3 0.1 (Formaldehyde) 0.2
010 1.2 0.8 2.3 0.1 (Formaldehyde) 0.2
011 1.2 0.8 2.3 0.1 (Formaldehyde) 0.2
012 1.2 0.8 2.3 0.1 (Formaldehyde) 0.2
013 1.2 0.8 2.3 0.1 (Formaldehyde) 0.2
Total permitted plant-wide
27.6 15.3 54.8 6.9 (Formaldehyde) 10.4
emissions':
A: Total facility-wide PTE as of the time of this permit issuance. Does not include modifications to seven (7)existing
permitted RICE,AIRS Points 007-013, or the addition of twenty-three(23)new unpermitted pieces of equipment,
AIRS Points 014-036, proposed in an application received by Division 5/27/2014.
B: These emissions do not include insignificant activities.
•
Page 3
Section 7—Non-Criteria/Hazardous Air Pollutants
Uncontrolled Are the Controlled Emission
Pollutant CAS# BIN Emission Rate emissions 1 r
(Ib/yr) reportable? Rate(b/y )
Benzene 71432 A 16,248.0 Yes 712.2
Toluene 108883 C 16,100.0 Yes 664.9
Ethylbenzene 100414 C 1,825.6 Yes 66.6
Xylenes 1330207 C 9,606.2 Yes 338.1
n-Hexane 110543 C 5,032.6 Yes 81.5
Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non-criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Section 8—Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory X Yes No
standard?
If"yes", complete the information listed below
AIRS Point Process Pollutant Regulatory Basis Test Method
001 01 VOC Regulation No. 3, Part B.,Section III.G.3 Stack Test
Section 9—Source Classification
Is this a new previously un-permitted source? X Yes No
What is this facility classification? True X Synthetic Major
Minor Minor
Classification relates to what programs? X Title V X PSD X NA NSR X MACT
Is this a modification to an existing permit? Yes X No
If"yes"what kind of modification? Minor Synthetic Major
Minor
Section 10—Public Comment
Does this permit require public comment per CAQCC Regulation 3? X Yes No
If"yes", for which pollutants?Why? VOC
For Reg. 3, Part B, III.C.1.a (emissions increase>25/50 tpy)? Yes X No
For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? X Yes No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No
Section 11 —Modeling
Is modeling required to demonstrate compliance with National Ambient Yes X No
Air Quality Standards (NAAQS)?
If"yes", for which pollutants?Why?
Page 4
AIRS Point Section 12—Regulatory Review
Re•ulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide
Section II.A.1 - Except as provided in paragraphs 2 through 6, no owner or operator of a
source shall allow or cause the emission into the atmosphere of any air pollutant which is
001 in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken
at 15-second intervals for six minutes. The approved reference test method for visible
emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A(July, 1992)) in all
subsections of Section II. A and B of this regulation.
Re•ulation 2—Odor
Section I.A - No person, wherever located, shall cause or allow the emission of odorous air
contaminants from any single source such as to result in detectable odors which are
001 measured in excess of the following limits: For areas used predominantly for residential or
commercial purposes it is a violation if odors are detected after the odorous air has been
diluted with seven (7) or more volumes of odor free air.
Regulation 3-APENs, Construction Permits, Operating Permits, PSD
Part A-APEN Requirements
001 Applicant is required to file an APEN since emissions one ton per year VOC in a
nonattainment area for ozone.
Part B—Construction Permit Exemptions
001 Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility
are greater than the two TPY threshold(Reg. 3, Part 8, Section ll.D.3.a)
Regulation 6 - New Source Performance Standards
001 None
Regulation 7—Volatile Organic Compounds
Is this source subject to the control requirements of MACT HH? (Regulation 8-Hazardous
Air Pollutants review). No
Is this source subject to the exemptions under MACT HH (i.e. throughput exemption less
001 than 3 MMSCFD or benzene exemption of less than 1984 Ib/yr)? Yes
Even though this source is subject to some requirements of MACT HH, it is not subject to
control requirements. Therefore, it can also be subject to Regulation 7 control
requirements.
Section XII.H:
Is this source located in the non-attainment area? Yes
001 This source is subject to Regulation 7, Section XII.H. Uncontrolled actual emissions of
volatile organic compounds from the still vent and vent from any gas-condensate-glycol
(GCG) separator (flash separator or flash tank), if present, shall be reduced by at least 90
percent through the use of air pollution control equipment.
Section XVII.D(State only enforceable).
001 Applicant is required to reduce VOC emissions from this dehydrator by at least 90% since
uncontrolled VOC emissions are greater than the 15.0 TPY threshold.
Page 5
Regulation 8—Hazardous Air Pollutants
MACT HH: If facility is MAJOR source for HAP(summation of HAPS of dehydrators
and fugitives greater than 25 TPY total or 10 TPY single HAP),then all glycol
dehydrators at this facility are subject to MACT HH. If facility is an area source of
HAP,only TEG dehydrators are subject to MACT HH.
1.Is facility a production field facility per 63.761 (Refer to Section 14 for definition)?Yes
2.If facility is defined as a production facility, then is it a major source of HAPS when
summing up dehydrator and flash tank emissions? No
3.If facility is NOT a production field facility(i.e. natural gas processing plant), then is it a
001 major source of HAPS when summing all HAP emissions from ALL HAP emitting
units? N/A
4.Is this facility considered MAJOR for HAPS? No
5.ls this source subject to MACT HH?Yes
6.WHY?
This facility is an area source of HAP and MACT HH area source requirements apply to this
TEG dehydrator. However, since benzene emissions from each unit will be less 1984 Ib/yr,
this source is only required to calculate and keep records demonstrating that benzene
emissions stay below this level.
Section 13—Aerometric Information Retrieval System Coding Information
Point Process Process Throughput Emission Pollutant/ Fugitive Emission Control
Description limit Factor CAS# (Y/N) Factor Source (%)
0.068 NOx No AP-42 0
lb/MMBtu
0.370 CO No AP-42 0
lb/MMBtu
73.510 VOC No GlyCalc 4.0 98.7%
lb/MMscf _
4,380 3.710 Benzene/ No GlyCalc 4.0 95.6%
Gly
01 cf per
Dehydrator year
001 3.676 Toluene/ No GlyCalc 4.0 95.9%
lb/MMscf 108883
0.417 Ethylbenzene/ No GlyCalc 4.0 96.4%
lb/MMscf 100414
2.193 Xylenes/ No GlyCalc 4.0 96.5%
lb/MMscf 1330207
1.149 n-Hexane/ No GlyCalc 4.0 98.4%
lb/MMscf 110543
SCC 31000227: Glycol Dehydrator: reboiler still stack
Section 14—Miscellaneous Application Notes
AIRS Point 001 Glycol Dehydrator
A permit will be issued because the uncontrolled VOC emissions are greater than two (2)TPY(non-
attainment area permit threshold).
In order to determine emissions, the operator used GRI GlyCalc 4.0. The source assumed the inlet gas
temperature of 120.0°F and pressure of 800.0 psig. The permitted lean glycol recirculation rate is 3.5
gallons per minute. The source specified flash tank operation at a temperature of 150.0°F and a pressure
of 125.0 psig, with 100% recompression/recycle of flash gas emissions. Still vent vapors are routed to
an air-cooled condenser permitted at a maximum outlet temperature of 160.0°F at a pressure of 12.4
psia. Condenser emissions are controlled by an enclosed combustor. The enclosed combustor is
granted a 95% reduction for the control of uncondensed vapors. Emission factors listed in Section 13
(AIRS Coding Information) of this analysis are based on the sum of flash tank and still vent emissions
from the GlyCalc report. Controlled emissions are based on 100% recompression/recycle of the flash
tank emissions and a 95%control of vapors from the condenser effluent stream.
Page 6
Section 14—Miscellaneous Application Notes Continued
AIRS Point 001 Glycol Dehydrator
The GlyCalc model was based off of a weighted average composite of six(6) representative extended
gas analyses from the following Bonanza Creek Energy Operating sales gas production lines: State North
Platte 24-21-26HNB (770 Mscf/day, 19.4%), State North Platte F-J-26HC (380 Mscf/day, 9.6%), State
North Platte F-J-26HNB (900 Mscf/day, 22.7%), State North Platte O24-K21-26HNC (510 Mscf/day,
12.8%), State North Platte P41-T44-26HNB (790 Mscf/day, 19.9%), and State North Platte P-T-26HNC
(620 Mscf/day, 15.6%). All six(6) gas analyses were sampled on May 16, 2014, and analyzed on May
21, 2014. The six (6) gas analyses were performed within less than a year of submittal of this permit
application. An updated extended gas analysis will be required because:
-This source is a new source and an actual sample was not available for emission calculations. A test
performed at the source once constructed will provide an accurate emissions sampling.
GlyCalc - Uncontrolled Emission factors
VOC = ((51.6188 ton/yr+ 109.3678 ton/yr)`2000 lb/ton)/(4,380 MMscf/yr) = 73.510 Ib/MMscf
Benzene = ((7.5389 ton/yr+ 0.5851 ton/yr)*2000 lb/ton)/(4,380 MMscf/yr) = 3.710 lb/MMscf
Toluene = ((7.639 ton/yr+ 0.4108 ton/yr)*2000 lb/ton)/(4,380 MMscf/yr) = 3.676 lb/MMscf
Ethylbenzene = ((0.883 ton/yr+ 0.0297 ton/yr)*2000 lb/ton)/(4,380 MMscf/yr) = 0.417 lb/MMscf
Xylenes = ((4.6929 ton/yr+ 0.1102 ton/yr)*2000 lb/ton)/(4,380 MMscf/yr) =2.193 lb/MMscf
n-Hexane = ((0.8387 ton/yr+ 1.6775 ton/yr)*2000 lb/ton)/(4,380 MMscf/yr) = 1.149 lb/MMscf
MACT HH includes requirements for both major and area sources of HAPs. The definition of major
source for MACT HH (63.761) states:
(3) For facilities that are production field facilities, only HAP emissions from glycol dehydration
units and storage vessels with the potential for flash emissions shall be aggregated for a major
source determination. For facilities that are not production field facilities, HAP emissions from all
HAP emission units shall be aggregated for a major source determination.
The following definitions from 63.761 are also needed to determine major source applicability:
Production field facilities means those facilities located prior to the point of custody transfer
Custody transfer means the transfer of hydrocarbon liquids or natural gas: after processing
and/or treatment in the producing operations, or from storage vessels or automatic transfer
facilities or other such equipment, including product loading racks, to pipelines or any other forms
of transportation. For the purposes of this subpart, the point at which such liquids or natural gas
enters a natural gas processing plant is a point of custody transfer.
Natural gas processing plant(gas plant) means any processing site engaged in the extraction of
natural gas liquids from field gas, or the fractionation of mixed NGL to natural gas products, or a
combination of both.
Based on the definitions above, this source qualifies as a production field facility.
Does this dehydrator have a reboiler?Yes
If Yes, what is the reboiler rated? 0.50 MMBtu/hr
Page 7
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