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Home My WebLink AboutDAQ-2024-0074201 DAQC-PBR148160001-23 Site ID 14816 (B1) MEMORANDUM TO: FILE – XCL RESOURCES, LLC – Cook 4-14B3 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Manager FROM: Stephen Foulger, Environmental Scientist DATE: June 22, 2023 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: May 12, 2023 SOURCE LOCATION: Cook 4-14B3 Lat: 40.314085 Long: -110.183985 Business Office: 3217 Montrose Boulevard #200 Houston, TX 77006 SOURCE TYPE: Tank Battery Uintah County API: 43-013-51162 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 2 DOGM current 12 month rolling production is: Search of DOGM records shows 5,613 bbls of production in the last 12 months. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: 3 General Provisions 4 VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] Out of Compliance. Oil tank thief hatch and PRV on tank top gathering line found leaking emissions at time of inspection. Thief hatch was repaired at time of inspection and tank top PRV was replaced by operator after the inspection. 5 Air pollution control equipment is designed and installed appropriately, maintained and operated to control emissions. [R307-501-4(2)] Out of Compliance. Combustor was found not combusting and pilot light unlit. Both of these issues were addressed at the time of inspection. 6 Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-2] In Compliance. Vessel lines are properly slopped. 7 Flare inlet lines are equipped with a fire arrestor, pressure gauge, inlet pressure regulat ing 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 lines appear to be properly designed and installed. 8 Pneumatic Controllers 9 Continuous bleed natural gas-driven pneumatic controllers are in compliance with 40 CFR 60.5390 or 60.5390a as applicable. Exemptions to tagging and record keeping requirements apply to controllers existing before 12/1/2015. [R307-502-4] In Compliance. No continuous bleed pneumatic controllers were found at this source. 10 Flares 11 Any flare has an operational auto-igniter. [R307-503-4] Out of Compliance. Inspection of source revealed auto-igniter installed on flare. Auto igniter failed to reignite pilot light. 12 Tank Truck Loading 13 Truck loading is done by bottom filling or submerged fill pipe [R307-504(1)] In Compliance. Source is set up for bottom or submerged filling. 3 15 Oil and Gas Industry Registration Requirement 16 The source is registered with the DAQ. [R307-505-3(3)] In Compliance. Search of DAQ records shows source is properly registered. 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 to be properly registered with the DAQ. 18 Storage Vessels 19 Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. Thief hatches found closed and latched 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. VOC's captured and sent to control device. Production for this source has also dropped below 8,000 bbls per 12 months of operation and is now voluntarily controlled. 21 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. Emergency storage vessel found free of emissions and properly controlled. 23 Upon modification, the well site was re-evaluated against the thresholds of R307-506-4(2). [R307-506-4(6)] In Compliance. No modifications to this source were found 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] Not Observed. Partial compliance inspection was conducted. These records were not evaluated at this time. 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. No visible emissions were observed at the time of inspection. 4 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)] Not Observed. Partial compliance inspection was conducted. These records were not evaluated at this time. 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] Not Observed. Partial compliance inspection was conducted. These records were not evaluated at this time. 29 Leak Detection and Repair 30 The source has an emissions monitoring plan. [R307-509-4(1)(a)] Not Observed. Partial compliance inspection was conducted. These records were not evaluated at this time. 31 The monitoring plan addresses difficult-to-monitor and unsafe-to-monitor components. [R307-509-4(1)(b)] Not Observed. Partial compliance inspection was conducted. These records were not evaluated at this time. 32 If emissions control is required, monitoring surveys are conducted to observe each fugitive emissions component for fugitive emissions. [R307-509-4(1)(c)] Not Observed. Partial compliance inspection was conducted. These records were not evaluated at this time. 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)] Not Observed. Partial compliance inspection was conducted. These records were not evaluated at this time. 34 Monitoring surveys are done with OGI equipment or by Method 21. [R307-509-4(1)(e)] Not Observed. Partial compliance inspection was conducted. These records were not evaluated at this time. 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)] Not Observed. Partial compliance inspection was conducted. These records were not evaluated at this time. 36 Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] Not Observed. Partial compliance inspection was conducted. These records were not evaluated at this time. 5 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] Not Observed. Partial compliance inspection was conducted. These records were not evaluated at this time. 38 Natural Gas Engines 39 Engines subject to R307-510 (does not have an AO, began operations, installed or modified after January 1, 2016) meet the following limits: Maximum Engine hp Emission Standards in (g/hp-hr) NOx CO VOC HC+NOx >25 hp and < 100 hp - 4.85 - 2.83 >100 hp 1.0 2.0 0.7 - [R307-510-4(1)] In Compliance. 40 Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)] In Compliance. 41 Affected engine exhaust vents are vertical and unrestricted. Stacks are 8' or greater if the site horsepower rating is 151 to 305 Stacks are 10' or greater if the site horse power rating is 306 or greater. [R307-510-4(3)] In Compliance. 42 Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] Not Observed. Partial compliance inspection was conducted. These records were not evaluated at this time. 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. 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)] Not Observed. Partial compliance inspection was conducted. These records were not evaluated at this time. 6 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 visible emissions observed at the time of inspection. 48 Dehydrators. 50 Monthly inspections are conducted according to 40 CFR 60.5416a(c) on the closed vent system, openings, thief hatches and bypass devices if emissions control is required, and defects are repaired within 15 days. [R307-506-4(5)] Not Observed. Partial compliance inspection was conducted. These records were not evaluated at this time 52 VOC control devices required by R307-507-4(1) have only been removed after a minimum of one year, and only if the rolling 12-month actual uncontrolled emissions are <4 tons VOC per year, individually or combined with emissions from storage vessels. [R307-507-4(4)] In Compliance. VOC control devices have not been removed. 53 Emission calculations are kept for all periods of operation if a control device is not installed at a source with a dehydrator. [R307-507-5(1)] Not Observed. Partial compliance inspection was conducted. These records were not evaluated at this time 54 Records of required vent system inspections at sources with dehydrators are kept for three years. [R307-507-5(2)] Not Observed. Partial compliance inspection was conducted. These records were not evaluated at this time 55 Emission Inventory: 56 An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. Search of DAQ records shows emissions inventory properly reported. 60 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. 7 COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Cook 4-14B3: Out of Compliance - The source was found out of compliance at the time of inspection. The operator promptly addressed found issues and is voluntarily controlling emissions with an enclosed combustor. Production has dropped below 8,000 bbls annually. No further action is recommended at this time. Inspection frequency is recommended to stay the same. RECOMMENDATION FOR NEXT INSPECTION: This source has dropped below 8,000 bbls of production in the last 12 months. The operator promptly addressed found issues. Due to the drop-in production, voluntary control of emission by enclosed combustor, and the cooperation of the operator in quickly addressing found issues, I recommend that the inspection frequency remain the same. ATTACHMENTS: