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HomeMy WebLinkAboutDAQ-2024-0079211 DAQC-PBR157490001-24 Site ID 15749 (B1) MEMORANDUM TO: FILE – XCL ASSETCO, LLC – Windy Ridge State 34-7 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Manager FROM: Stephen Foulger, Environmental Scientist DATE: March 20, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: February 8, 2024 SOURCE LOCATION: Windy Ridge State 34-7 Lat: 40.268407 Long: -109.977457 Business Office: 600 North Shepherd Drive Suite 390 Houston, TX 77007 SOURCE TYPE: Tank Battery Duchesne County API: 4301333982 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: 21,750 Estimated Oil BBL. 2 DOGM current 12 month rolling production is: 3,637. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Pneumatic controllers and Tanks General Provisions VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] Out of Compliance. Emissions were found coming from two oil tank thief hatches and a dump valve in the separator shed. 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. 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. Upon modification, the well site was re-evaluated against the thresholds of R307-506-4(2). [R307-506-4(6)] In Compliance. Source was found unmodified at the time of inspection. 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. 3 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 were 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. Source was found properly reported in the 2020 emissions inventory. 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 Windy Ridge State 34-7: Out of Compliance - This source was found non-compliant at the time of inspection. Emissions were found coming from two oil tank thief hatches and a dump valve in the separator shed. Operator was notified of found issues and has addressed all found leaks. No further action is recommended at this time. Recommend to increase inspection frequency. RECOMMENDATION FOR NEXT INSPECTION: Recommend to increase inspection frequency. ATTACHMENTS: