The URL can be used to link to this page

Home My WebLink AboutDAQ-2024-0069561 DAQC-PBR101699001-24 Site ID 101699 (B1) MEMORANDUM TO: FILE – XCL ASSETCO, LLC – 25-1B-22 Pad THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Manager FROM: Stephen Foulger, Environmental Scientist DATE: February 26, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: February 12, 2024 SOURCE LOCATION: 25-1B-22 Pad Lat: 40.28672 Long: -110.05855 Business Office: 600 North Shepherd Drive, Suite 390 Houston, TX 77007 SOURCE TYPE: Tank Battery Duchesne County API: 4301354126, 4301354127, 4301354128, 4301354129, 4301354130, 4301354131 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 has Line Power The source registered: 1,400,000 Estimated Oil BBL. 2 DOGM current 12 month rolling production is: 1,309,156 Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Pneumatic, Tank 3 General Provisions 4 VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] In Compliance. VOCs found responsibly controlled. 5 Air pollution control equipment is designed and installed appropriately, maintained and operated to control emissions. [R307-501-4(2)] In Compliance. Control equipment found maintained and installed. 6 Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-2] In Compliance. Vessel vent lines found properly sloped at the time of inspection. 7 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] In Compliance. Flare inlet found properly engineered at the time of inspection. 8 10 Flares 11 Any flare has an operational auto-igniter. [R307-503-4] In Compliance. Flare found with operational auto-ignitor installed at the time of inspection. 12 Tank Truck Loading 13 Truck loading is done by bottom filling or submerged fill pipe [R307-504(1)] In Compliance. Truck loading done by bottom or submerged filling at the time of inspection. 14 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 lines found available for use at the time of inspection. 15 Oil and Gas Industry Registration Requirement 16 The source is registered with the DAQ. [R307-505-3(3)] In Compliance. Source found properly registered at the time of inspection. 17 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. 3 18 Storage Vessels 19 Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. Thief hatches found closed, latched and in good repair at the time of inspection. 20 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. VOCs found properly routed at the time of inspection. 24 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] In Compliance. These records were reviewed and found to be compliant at the time of inspection. 25 VOC Control Devices 26 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. Control device found operating at proper destruction level with no visible emissions. 27 Monthly AVO inspections are conducted on VOC control devices and associated equipment, and corrective actions are taken within 15 days. [R307-508-3(3)] In Compliance. These records were reviewed and found to be compliant at the time of inspection. 28 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] In Compliance. These records were reviewed and found to be compliant at the time of inspection. 29 Leak Detection and Repair 30 The source has an emissions monitoring plan. [R307-509-4(1)(a)] In Compliance. These records were reviewed and found to be compliant at the time of inspection. 31 The monitoring plan addresses difficult-to-monitor and unsafe-to-monitor components. [R307-509-4(1)(b)] In Compliance. These records were reviewed and found to be compliant at the time of inspection. 4 32 If emissions control is required, monitoring surveys are conducted to observe each fugitive emissions component for fugitive emissions. [R307-509-4(1)(c)] In Compliance. These records were reviewed and found to be compliant at the time of inspection. 33 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)] In Compliance. These records were reviewed and found to be compliant at the time of inspection. 34 Monitoring surveys are done with OGI equipment or by Method 21. [R307-509-4(1)(e)] In Compliance. Monitoring is conducted using OGI equipment. 35 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)] In Compliance. These records were reviewed and found to be compliant at the time of inspection. 36 Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] In Compliance. These records were reviewed and found to be compliant at the time of inspection. 37 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] In Compliance. These records were reviewed and found to be compliant at the time of inspection. 38 43 Associated Gas Flaring 44 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 at the time of inspection. 45 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)] In Compliance. No events were reported at the time of inspection. 5 46 Visible Emissions 47 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 emissions were observed at the time of inspection. 48 Emission Inventory: 55 An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. Source began production after the 2020 emissions inventory. 56 NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution [40 CFR 60 Subpart OOOO] In Compliance. 60 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to 25-1B-22 Pad: In Compliance - This source was found compliant at the time of inspection. This is a high-production source. Recommend to keep inspection frequency the same. RECOMMENDATION FOR NEXT INSPECTION: Recommend to keep inspection frequency the same. ATTACHMENTS: