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Home My WebLink AboutDAQ-2024-0115121 DAQC-PBR155800001-24 Site ID 15580 (B1) MEMORANDUM TO: FILE – BERRY PETROLEUM COMPANY, LLC – State Tribal 16-10-54 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Manager FROM: Fred Goodrich, Environmental Scientist DATE: August 20, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: June 19, 2024 SOURCE LOCATION: State Tribal 16-10-54 Lat: 40.05518 Long: -110.31478 Business Office: 11117 River Run Boulevard Bakersfield, CA 93311 SOURCE TYPE: Tank Battery Duchesne County API: 4301350245, 4301352561 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 JJJJ, 40 CFR 60 Subpart OOOO. , - 2 SOURCE EVALUATION: Site Type: PBR-Uncontrolled No Flare Controls Site powered by Engine The source registered: 4,204 Estimated Oil BBL. DOGM current 12 month rolling production is: 4,806 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-42 Mfg Year - Pre 2008 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 4 VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] In Compliance. The expected components were found installed. The DAQ observed the installation for a cycle and it seems to be operating as expected. 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. This source does not use continuous bleed natural gas-driven pneumatic controllers. 13 Truck loading is done by bottom filling or submerged fill pipe. [R307-504(1)] In Compliance. The truck loading area is suitable for submerged loading and it is routine for truck drivers to load this way. 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. 3 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. Berry Petroleum had production totals calculated and prepared for the DAQ. 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. 2 engines are installed. One is an Arrow C-101 that is less than 25 HP. The other is an old Ajax E-42 which was likely manufactured well before 2016. These pumpjack engines are subject to NSPS JJJJ or NSPS ZZZZ standards instead. 42 Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. Engines installed before 2016 are not under obligation to retain certifications or stack tests for life. 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. 55 Emission Inventory: 56 An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. The operator submitted for the 2020 emissions inventory. The results for the 2023 inventory have not yet been released. 4 Applicable Federal Regulations: 59 NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. In Compliance. The Ajax engine at this source is not certified. Stack testing may or may not have been performed but, the record retention time limit for this testing has expired. The maintenance provisions have been met. The Arrow engine is less than 25HP 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. This source is permitted with the State of Utah with legal and enforceable limits. They do not have the production that would qualify under 40 CFR (60) OOOO for a tank affected facility. There are no other affected facilities that are installed. PREVIOUS ENFORCEMENT ACTIONS: None COMPLIANCE STATUS & RECOMMENDATIONS: In regards to: State Tribal 16-10-54: In Compliance - The source was surveyed by AVO and with an OGI camera and was found to be well-kept with no visible or fugitive emissions. Requested records were provided in a timely manner and reviewed at the local field office. RECOMMENDATION FOR NEXT INSPECTION: The DAQ has no recommendations for the next inspector other than what are customary. The DAQ recommends the inspection frequency of this source be reduced. The DAQ was joined by Berry personnel during the site inspection. ATTACHMENTS: None