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Home My WebLink AboutDAQ-2024-0082751 DAQC-PBR083350001-23 Site ID 8335 (B1) MEMORANDUM TO: FILE – XCL RESOURCES, LLC - Butcher Butte Pad 22-3C-22 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Stephen Foulger, Environmental Scientist DATE: October 23, 2023 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: September 28, 2023 SOURCE LOCATION: Butcher Butte Pad 22-3C-22 Lat:40.28805 Long: -110.10428 Business Office: 3217 Montrose Blvd #200 Houston, TX 77006 SOURCE TYPE: Tank Battery Duchesne County API: 4301353698, 4301353907 SOURCE CONTACTS: Lauren Brown, Corporate Environmental Contact Phone: 713-808-9406, Email: lauren@xclresources.com OPERATING STATUS: Operating PROCESS DESCRIPTION: Oil and gas products are brought to the surface. These products go through a separator where the oil and any water products are sent to storage tanks and the gas is used to power equipment on site (pump jack engine, tank heater, separator, flare, combustor, etc.) Any remaining gas is sent to a pipeline that feeds a local gas plant. The oil and process water in the storage tanks is loaded into tanker trucks and hauled off-site for processing and disposal. APPLICABLE REGULATIONS: Utah Administrative Code (UAC) R307-500 Series for the Oil and Gas Industry, and UAC R307-201: Emission Standards: General Emission Standards; and UAC R307-150: Emission Inventories, and 40 CFR 60 Subpart OOOO. SOURCE EVALUATION: Site Type: PBR- Controlled Controlled by flare Site powered by Engine The source registered: 1000000 Estimated Oil BBL. 2 DOGM current 12 month rolling production is: 91,493. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Engine - Engine - Natural Gas 4-Stroke Lean Burn Make - Cummins Model - KTA19GC Mfg Year - 2015 Horse Power - 380 Combustion - Natural Gas, Pneumatic, Tank General Provisions VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] Out of Compliance. Crude oil tank thief hatch found leaking at the time of inspection. Air pollution control equipment is designed and installed appropriately, maintained and operated to control emissions. [R307-501-4(2)] In Compliance. Crude oil tank thief hatch found leaking at the time of inspection. Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-2] In Compliance. Vent lines found appropriately sloped. Flare inlet lines are equipped with a fire arrestor, pressure gauge, inlet pressure regulating valve and other components according to the engineering design, the manufacturers specifications or good practices for safety and emissions control. [R307-501-2] Out of Compliance. No pressure inlet control found on flare inlet. Flares Any flare has an operational auto-igniter. [R307-503-4] In Compliance. Operational auto-igniter found installed at the time of inspection. Tank Truck Loading Truck loading is done by bottom filling or submerged fill pipe [R307-504(1)] In Compliance. Truck loading set up for bottom or submerged filling. A vapor capture line is used during truck loading if subject to storage vessel emissions controls of R307-506-4(2). Effective 7/1/2019 for sources existing before 1/1/2018, and upon construction for new sources.[R307-504-4(2)] In Compliance. Vapor capture line available for use during truck loading. Oil and Gas Industry Registration Requirement The source is registered with the DAQ. [R307-505-3(3)] In Compliance. Source found properly registered at the time of inspection. 3 Registration has been updated within 30 days of a company name change, removal or addition of control devices, or termination of operations. [R307-505-3(3)] In Compliance. Source found properly registered at the time of inspection. Storage Vessels Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. Thief hatches found closed and latched at the time of inspection. VOCs from storage vessels are recycled, recovered or controlled by a device that is compliant with R307-508. Exempt if <8000 bbls crude oil per year, <2000 bbls condensate, or if uncontrolled emissions are <4 tons VOC per year.[R307-506-4(2)(a)] In Compliance. VOC's from storage vessels routed to a control device. Emissions from emergency storage vessels are controlled according to R307-506-4(2), or are only used in emergencies, are emptied within 15 days of receiving fluids and are equipped with a liquid level gauge. [R307-506-4(4)] In Compliance. Upon modification, the well site was re-evaluated against the thresholds of R307-506-4(2). [R307-506-4(6)] In Compliance. Records for each of the following are kept for three years: Storage vessel vent system inspections (openings, thief hatches, pressure relief devices, bypasses, etc.), if required Monthly crude oil throughput Emission calculations, actuals and sampling data when used to justify an exemption to storage vessel rules Emergency storage vessel usage (dates used, emptied, and volumes), if not controlled per R307-506-4(2) [R307-506-5] Out of Compliance. XCL failed to produce requested records. VOC Control Devices The VOC control device(s) required by R307-506 or R307-507 has a control efficiency of 95% or greater, operates with no visible emissions and has an operational auto-igniter according to R307-503. [R307-508-3(1)] In Compliance. No visible emissions observed at the time of inspection. Monthly AVO inspections are conducted on VOC control devices and associated equipment, and corrective actions are taken within 15 days. [R307-508-3(3)] Out of Compliance. XCL failed to produce requested records. 4 The following records are kept: VOC control device efficiency, for life of the equipment Manufacturer operating and maintenance instructions for VOC control devices, for life of the equipment AVO inspections of the VOC control device(s), associated equipment and any repairs, for 3 years. [R307-508-4] Out of Compliance. XCL failed to produce requested records. Leak Detection and Repair The source has an emissions monitoring plan. [R307-509-4(1)(a)] Out of Compliance. XCL failed to produce requested records. The monitoring plan addresses difficult-to-monitor and unsafe-to-monitor components. [R307-509-4(1)(b)] Out of Compliance. XCL failed to produce requested records. If emissions control is required, monitoring surveys are conducted to observe each fugitive emissions component for fugitive emissions. [R307-509-4(1)(c)] Out of Compliance. XCL failed to produce requested records. Initial monitoring surveys were within 60 days after startup for new sources. Subsequent surveys are semi-annual for regular components, annual for difficult-to-monitor components, and as required by the monitoring plan for unsafe-to-monitor components. [R307-509-4(1)(d)] Out of Compliance. XCL failed to produce requested records. Monitoring surveys are done with OGI equipment or by Method 21. [R307-509-4(1)(e)] In Compliance. Fugitive leaks are repaired within 15 days unless infeasible, unsafe, etc., as stated in the rule, which require repair within 24 months per the rule. [R307-509-4(1)(f)] Out of Compliance. XCL failed to produce requested records. Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] Out of Compliance. XCL failed to produce requested records. The following records are kept: The emissions monitoring plan, for life of the site LDAR inspections, repairs and resurveys, for 3 years [R307-509-5] Out of Compliance. XCL failed to produce requested records. 5 Associated Gas Flaring Associated gas is routed to a process unit for combustion, a sales pipeline or an operating VOC control device, except in an emergency. An emergency release is unanticipated, temporary, infrequent, unavoidable, =24 hrs. and is not due to operator negligence. Low pressure gas from working loss, breathing loss and oil flashing is not "associated gas." [R307-511-4(1)] In Compliance. Associated gas found properly routed and controlled. The following records are kept: The time and date of event Volume of emissions Any corrective action taken for 3 years.[R307-511-5(1)(a)(b)] Out of Compliance. XCL failed to produce requested records. Visible Emissions Visible emissions, except for unavoidable irregularities that do not exceed three minutes, are within the following opacity limits: Installations constructed on or before 4/25/1971 40% Installations constructed after 4/25/1971 20% Gasoline engines 0% Diesel engines manufactured after 1/1/1973 20% Diesel engines manufactured before 1/1/1973 40% Note: Required VOC control devices shall have no visible emissions per R307-508-3.[R307-201-3] In Compliance. No visible emissions observed at the time of inspection. Emission Inventory: An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. Emissions inventory found properly reported. NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution [40 CFR 60 Subpart OOOO] In Compliance. PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to: Butcher Butte Pad 22-3C-22: Out of Compliance -XCL failed to produce records. This site was also found out of compliance at the time of inspection. Compliance advisory was issued. Following review of compliance advisory response and meeting held with XCL an NFA was issued. Recommend to increase inspection frequency. 6 RECOMMENDATION FOR NEXT INSPECTION: Recommend to increase inspection frequency. ATTACHMENTS: Compliance Advisory State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executiv.e Director DTVISION OF AIR QUALITY Bryce C. Bird Director November 6,2023 DAQC-I169-23 Site ID 8335 (B1) Sent Via Certified Mail No. 70190700000208346153 Lauren Brown XCL Resourcas, LLC 32 I 7 Montrose Boulevard #200 Houston, TX77006 Dear Ms. Brown, Re: Compliance Advisory - XCL Resources, LLC - Butcher Butte Pad22-3C-22, Duchesne County On September 28, 2023, a representative of the Utah Division of Air Quality (DAQ) conducted an inspection of XCL Resources, LLC Butcher Butte Pad22-3C-22located at latitude 40.28805, longitude -1 1 0. 1 0428, Duchesne County. The DAQ observed the following regulations of concern: R307-506-4 - Storage Vessels R307-509- 4 - Leak Detection and Repair R307-511-4 - Associated Gas Flaring R307-501-4 - General Requirements R307-508-3 - VOC Control Devices These findings may be a violation of Utah Air Conservation Rules. XCL Resources, LLC Butcher Butte Pad22-3C-22 is required to comply with the above regulations. A written response to this letter is required within ten (10) business days of receipt of this letter. 195 North 1950 West. Salt Lake City, UT Mailing Address: P.O. Box 144820 . Salt Lake City, UT 84114-4820 Telephone (801) 5364000. Fax (801) 5364099. T.D.D. (801) 903-3978 hw.deq.utah.gov Printed on 100% recycled paper DAQC-I169-23 Page2 Additional detaits about the above observations and regulations are included with this letter. Please contact Stephen Foutger at (801) 662-8650 or sfoulger@utah.gov if you have any additional questions. Minor Source Oil and Gas Compliance Section Manager RO:SF:rh cc: TriCounty Health Department Alan Humpterys, UDAQ, Minor NSR Section Manager Sincerely, ,rea%A Rik Ombach DAQC-I169-23 Page 3 Potential Violation(s) On September 28,2023, an inspector from the DAQ attempted an inspection at XCL Resources, LLC Butcher Butte Pad22-3C-22located at latitude 40.28805, longitude -110.10428, Duchesne County. At the time of the inspection, the DAQ documented the following potential violation(s): Reouirement & Rule Comments & Observations Initial monitoring surveys were within 60 days after startup for new sources. Subsequent surveys are semi-annual forregular components, annual for diffrcult-to-monitor components, and as required by the monitoring plan for unsafe-to-monitor components. [R307-509-4(l Xd)] XCL failed to produce requested records. The source has an emissions monitoring plan. [R307-s0e-a(l)(a)] XCL failed to produce requested records. The following records are kept: VOC control device efficiency, for life of the equipment Manufacturer operating and maintenance instructions for VOC control devices, for life of the equipment AVO inspections of the VOC control device(s), associated equipment and any repairs, for 3 years. [R307-5084] XCL failed to produce requested records. Resurvey of the repaired components is completed within 30 days. [R307-s09-a( I )(g)] XCL failed to produce requested records. The monitoring plan addresses difficult-to-monitor and unsafe- to-monitor components. [R307-509-4(1Xb)] XCL failed to produce requested records. The following records are kept: The time and date of event Volume of emissions Any corrective action taken for 3 years. [R307-s 1 1 -s( I XaXb)] XUL talled to produce requested records, Monthly AVO inspections are conducted on VOC control devices and associated equipment, and corrective actions are taken within 15 days. [R307-508-3(3)] XCL failed to produce requested records. If emissions control is required, monitoring surveys are conducted to observe each fugitive emissions component for tugitive emissions. [R307-509-4( lXc)] )(UL larled to produce requested records. DAQC-I169-23 Page 4 The purpose of a Compliance Advisory (CA) is to document observations made by the DAQ. You are responsible for complying with the Utah Air Conservation Rules. There are possible administrative and civil penalties for failing to do so. Section 19-2-115 of the Utah Code Annotated provides that violators of the Utah Air Conservation Act and/or any order issued there under may be subject to a civil penalty of up to $10,000 per day for each violation. When considering if the potential violation(s) are resolved, the DAQ will consider the written response to this CA. Responses may include information demonstrating compliance with the regulations or an anticipated schedule from your company to become compliant with the applicable regulations. Once received, the DAQ will review your response and the CA may be revised as a result of that review. Failure to respond in writing within ten (10) business days of receipt of this CA shall be considered in the escalation of subsequent enforcement action and assessment of penalties. The following records are kept: The emissions monitoring plan, for life of the site LDAR inspections, repairs and resurveys, for 3 years [R307-s0e-s] XCL failed to produce requested records. Fugitive leaks are repaired within 15 days unless infeasible, unsafe, etc., as stated in the rule, which require repair within 24 months per the rule. [R307-5094(1X0] XCL failed to produce requested records. Records for each of the following are kept for three years: Storage vessel vent system inspections (openings, thief hatches, pressure relief devices, b1ryasses, etc.), if required Monthly crude oil throughput Emission calculations, actuals and sampling data when used to justify an exemption to storage vessel rules Emergency storage vessel usage (dates used, emptied, and volumes), if not controlled per R307-506-4(2)[R307-506-5] XCL failed to produce requested records. Flare inlet lines are equipped with a fire arrestor, pressure gauge, inlet pressure regulating valve and other components according to the engineering design, the manufacturers specifications or good practices for safety and emissions control. [R307-s014(2a)] No back-pressure control device was fbund installed on the flare inlet at the time of inspection. XCL has placed an order for this control measure and will install it once it has been received. VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-s01-4(1)] Crude oil tank thief hatch found leaking emissions at the time of inspection. Air pollution control equipment is designed and installed appropriately, maintained and operated to control emissions. [R307-s014(2)] Crude oil tank thief hatch found leaking emissions at the time of inspection. DAQC-I169-23 Page 5 Possible DAQ actions to resolve a CA include: No Further Action Letter, Warning Letter, Early Administrative Settlement with reduced civil penalty, Settlement Agreement with civil penalty, or Notice of Violation and Order to Comply. This CA does not limit or preclude the DAQ from pursuing additional enforcement options. Additionally, this CA does not constitute abar to enforcement action for conditions that the DAQ did not observe or evaluate, or any other conditions found during future inspections. A meeting may be requested to discuss this CA. Please contact Stephen Foulger at (801) 662-8650 or sfoulger@utah.gov if you would like to request a meeting or if you have any questions. ililrillr llil rllilr ilt ilruil ililil ilIil tll Iilil t sPsTRACloitG# Flrst€lass Mall Postrage & Fees Pald USPS Permit No. G-10 II$J-II- DAoc- lttl -L3 : Please print pur name, addiess, tr LUTAH DIVISION OF AIR QUALITY PcorwLrANCE sECTroN ,,$no Box t44BZo gSALTTAKE CrTY UT 84114-4820 Fomplete items 1,2, and 3' I ii", *rt rame and'9,9t":-""1t*- IJ'ir,iiil" Irn return the card to vou' . ilactiil *td to the back 9*f the mailpiece' Agent o. 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