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Home My WebLink AboutDAQ-2024-0105371 DAQC-PBR046890001-24 Site ID 4689 (B1) MEMORANDUM TO: FILE – WESCO OPERATING, INC. – Cane Creek Unit 12-1/12-2 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Manager FROM: Paul Bushman, Environmental Scientist DATE: September 18, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: September 12, 2024 SOURCE LOCATION: Lat: 38.554514 Long: -109.774345 Business Office: Wesco Operating, Inc. 120 South Durbin Street P.O. Box 1650 Casper, WY 82602 SOURCE TYPE: Tank Battery Grand API: 4301950009 SOURCE CONTACTS: Dave Weinert, Corporate Environmental Contact Phone: (307) 577-5329 Email: davew@kirkwoodcompanies.com Jeff Miller, Local Contact Email: jeffm@wesco-operating.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. Federal Subpart: 40 CFR 60 Subpart OOOO. 2 SOURCE EVALUATION: Site Type: PBR-Controlled Voluntarily controlled by flare, site powered by engine. The source registered: 22,324 Estimated Oil BBL. DOGM current 12 month rolling production is: 6,534 BBLs. 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 Rich Burn Make - Cummins Model - G5.9 Mfg Year - 2013 Horse Power - 99 Combustion - Natural Gas, Engine - Engine - Natural Gas 4- Stroke Rich Burn Make - Olympia Model - G35F3S Mfg Year - 2007 Horse Power - 150 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)] In Compliance. VOC emissions appeared to be minimized as reasonably as practicable. Air pollution control equipment is designed and installed appropriately, maintained and operated to control emissions. [R307-501-4(2)] In Compliance. Control equipment appeared to be installed and maintained appropriately to control emissions. Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-2] In Compliance. Vessel vent lines were sloped away from the combustor inlets. 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. Combustor inlets appeared to be properly designed. Pneumatic Controllers 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. This source does not use continuous bleed natural gas-driven pneumatic controllers. Flares Any flare has an operational auto-igniter. [R307-503-4] In Compliance. The enclosed combustors are equipped with an operational auto-igniter. 3 Tank Truck Loading Truck loading is done by bottom filling or submerged fill pipe [R307-504(1)] In Compliance. Trucks are loaded via 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. The source is equipped with vapor capture lines. Oil and Gas Industry Registration Requirement The source is registered with the DAQ. [R307-505-3(3)] In Compliance. Source was properly registered at the time of inspection. Storage Vessels Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. Thief hatches were found closed and latched during the 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. Emissions are voluntarily controlled from tanks. 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. Wesco operating checks storage vessels during the daily inspections and empties the storage vessels if needed. 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 are kept as required. See attachments. 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. The source is voluntarily controlled. The enclosed combustors were operating with no visible emissions, were equipped with an operational auto-igniter, and have a control efficiency of 95% or greater. See attachments. 4 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. Monthly AVO inspections are conducted at the source. See attachments. 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. Records are kept as required. See attachments. Leak Detection and Repair The source has an emissions monitoring plan. [R307-509-4(1)(a)] In Compliance. The source has an emissions monitoring plan. 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. Monitoring surveys are conducted as required. See attachments. 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. Monitoring surveys are conducted semi-annually. See attachments. Monitoring surveys are done with OGI equipment or by Method 21. [R307-509-4(1)(e)] In Compliance. An OGI camera is used to conduct the monitoring surveys. 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. Leaks are repaired within the 15 day timeframe. See attachments. Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] In Compliance. Resurveys are conducted within the required timeframe. See attachments. 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. Records are kept as required. See attachments. 5 Natural Gas Engines 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. The Cummins G5.9 SN:73560844 was stack tested on December 29, 2022. See DAQC-080-23. The Olympian generator was replaced with a PSI 5.7 SN:22765 which was stack tested on June 29, 2023. See DAQC-764-23. Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)] In Compliance. The Cummins G5.9 SN:73560844 was stack tested on December 29, 2022. See DAQC-080-23. The Olympian generator was replaced with a PSI 5.7 SN:22765 which was stack tested on June 29, 2023. See DAQC-764-23. 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. Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. Records are kept as required. 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 appeared to be properly routed during the inspection. 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. 6 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 from any point during the inspection. Dehydrators: Emission Inventory: An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. An emission inventory was submitted in 2021 for the 2020 operating year. 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: Compliance Advisory (DAQC-1213-22) sent September 14, 2022, for leaking thief hatches due to the knockout being full of liquid. Additionally, the Cummins 5.9 engine and Olympian generator did not have an initial stack test. ESA (DAQC-315-23) sent March 17, 2023, addressing the above CA. The Olympian generator was replaced with a PSI 5.7L engine. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to the site, the overall status is: In Compliance. The source was surveyed with an OGI camera and found to be in compliance at the time of inspection. RECOMMENDATION FOR NEXT INSPECTION: None. RECOMMENDATIONS FOR NSR: None. ATTACHMENTS: Applicable supporting documentation included. Combustor Type Month Oil Gas Water Oil Gas Water Oil Gas Water Oil Gas Water Oil Gas Water Oil Gas Water Oil Gas Water Oil Gas Water Aug-23 4 0 0 231 130 166 574 674 2747 34 1 0 927 536 482 0 0 0 18 0 0 391 58 135 Sep-23 180 11 0 281 123 147 88 152 619 307 2 0 913 673 613 0 1 204 13 0 0 379 56 58 Oct-23 77 3 0 318 110 187 350 399 1309 147 1 0 1185 684 975 313 293 325 21 0 0 375 58 68 Nov-23 90 30 0 483 206 200 523 466 1977 19 6 0 802 1500 694 227 259 231 23 5 0 368 56 60 Dec-23 77 2 0 586 210 145 603 441 2219 0 0 0 820 2859 576 15 118 192 21 3 0 390 58 65 Jan-24 29 1 0 242 310 111 565 643 2189 0 0 0 825 657 497 0 0 0 15 0 0 323 173 43 Feb-24 79 0 0 226 258 111 582 489 3138 0 0 0 1065 533 630 0 0 0 21 0 0 415 167 77 Mar-24 56 0 0 26 10 69 688 437 3168 0 0 0 1108 717 781 0 12 260 21 0 0 383 199 55 Apr-24 49 0 0 0 0 0 667 943 2884 0 0 0 1063 730 657 0 0 0 17 0 0 393 192 65 May-24 49 0 0 0 24 124 786 1240 3120 74 70 0 1687 1424 854 372 335 285 25 0 0 383 198 57 Jun-24 19 0 0 837 391 109 287 465 1152 246 397 0 1021 1881 892 239 189 297 15 0 0 365 199 72 Jul-24 28 0 0 478 312 103 821 1146 2880 105 255 0 1275 1762 524 188 213 175 21 0 0 370 199 37 Total 737 47 0 3708 2084 1472 6534 7495 27402 932 732 0 12691 13956 8175 1354 1420 1969 231 8 0 4535 1613 792 Cane Creek 24-1 48" HVECD Cane Creek 24-2 48" HVECD Cane Creek 12-1 48" HVECD Cane Creek 36-3 48" HVECD Cane Creek 2-1 60" ECD Cane Creek 12-2 48" HVECD Cane Creek 36-1 48" HVECD Cane Creek 36-2 48" HVECD