Loading...
HomeMy WebLinkAboutDAQ-2024-0045451 DAQC-PBR155950001-23 Site ID 15595 (B1) MEMORANDUM TO: FILE – BERRY PETROLEUM COMPANY, LLC – LC Tribal 15-26-56 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Fred Goodrich, Environmental Scientist DATE: September 15, 2023 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: September 15, 2023 SOURCE LOCATION: LC Tribal 15-26-56 Lat: 40.011952 Long: -110.524553 Business Office: 11117 River Run Boulevard Bakersfield, CA 93311 SOURCE TYPE: Tank Battery Duchesne County API: 4301350871, 4301351381 SOURCE CONTACTS: Jon Armstrong, Corporate Environmental Contact Phone: (661) 293-8211, Email: jarmstrong@bry.com Matt Guest, Local Contact Email: mguest@bry.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 IIII, 40 CFR 60 Subpart JJJJ, 40 CFR 60 Subpart OOOO. , - 2 SOURCE EVALUATION: Site Type: PBR-Uncontrolled No Flare Controls Site powered by engine The source registered: 2,241 Estimated Oil BBL. DOGM current 12 month rolling production is: 3,063 BBLs. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Engine - Engine - Natural Gas 2-Stroke Lean Burn Make - Ajax Model - E-565 Mfg Year - 2011 Horse Power - 40 Combustion - Field Gas, Engine - Engine - Natural Gas 4-Stroke Rich Burn Make - Arrow Model - C-101 Mfg Year - Post 2008 Horse Power - 24.5 Combustion - Field Gas, Pneumatic, Tank 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 December 1, 2015. [R307-502-4] In Compliance. This source does not use continuous bleed controllers as described in 40 CFR 60.5365(d)(1). 15 Oil and Gas Industry Registration Requirement 16 The source is registered with the DAQ. [R307-505-3(3)] In Compliance. 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. 18 Storage Vessels 19 Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. All hatches were found closed at the start of the evaluation. 23 Upon modification, the well site was re-evaluated against the thresholds of R307-506-4(2). [R307-506-4(6)] In Compliance. The DAQ did not identify any modifications or unauthorized equipment. 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. Records were observed at the local Berry Petroleum LLC office. 3 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. Upon inspection the engine exhaust stack vents were found correctly vertical. 42 Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. Observed. 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 were detected. 55 Emission Inventory: 56 An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. Berry Petroleum submitted for the 2020 emissions inventory. 58 NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines [40 CFR 60 Subpart IIII] In Compliance. 59 NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines [40 CFR 60 Subpart JJJJ] In Compliance. 4 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. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to: LC Tribal 15-26-56: In Compliance - This source was found to be clean and well-kept with no visible or fugitive emissions. The source was inspected by OGI camera and found to be free of leaks. RECOMMENDATION FOR NEXT INSPECTION: The DAQ has no recommendations for the next inspector other than what are customary. ATTACHMENTS: None.