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Home My WebLink AboutDAQ-2024-0115131 DAQC-CI156210002-24 Site ID 15621 (B1) MEMORANDUM TO: FILE – BERRY PETROLEUM COMPANY, LLC – LC Tribal 9-27-56 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Fred Goodrich, Environmental Scientist DATE: August 13, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Duchesne County INSPECTION DATE: May 30, 2024 SOURCE LOCATION: Lat 40.016639, Lon -110.540773 Rural Duchesne County DIRECTIONS: SOURCE CONTACTS: Aaron Hoopes ahoopes@bry.com OPERATING STATUS: Operating PROCESS DESCRIPTION: Oil and gas products are brought to the surface using a pumping unit. These products go through a separator where the oil and any water products are sent to storage tanks and the 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: Approval Order (AO) DAQE-AN156210001-16, dated October 25, 2016 NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines, MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines SOURCE EVALUATION: Name of Permittee: Permitted Location: Berry Petroleum Company, LLC - LC Tribal 9-27-56 11117 River Run Boulevard NESE ¼ Sec 27 T5S R6W Bakersfield, CA 93311 Duchesne County, UT SIC Code: 1311: (Crude Petroleum & Natural Gas) , - 2 Section I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] Status: In Compliance. I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] Status: In Compliance. This source did not exceed any of the limits set in the AO. I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] Status: In Compliance. Modifications to the VCS are more than likely to improve the control of tank emissions. The DAQ inspected the installation and verified the proper operation. I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] Status: In Compliance. The recordkeeping procedures are found to be orderly and complete. I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] Status: In Compliance. The VCS and ECD components have been upgraded this year to include an inlet pressure regulating valve and burner management system I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] Status: In Compliance. No breakdowns reported. I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. Emission totals for the criteria pollutants were reported to the 2020 inventory for this source. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 LC Tribal 9-27-56 Production Tank Battery II.A.2 Pump-Jack Engines Maximum Site-wide Rating: 130 hp combined Maximum Single Engine Rating: 65 hp Fuel: Natural Gas 3 II.A.3 Boilers & Heaters Includes: heater treaters, separators and tank heaters Maximum Total Capacity: 9.0 MMBtu/hr combined Fuel: Natural Gas II.A.4 Oil Storage Tanks Maximum Total Capacity: 2,400 barrels combined II.A.5 Produced Water Storage Tanks Maximum Total Capacity: 800 barrels combined II.A.6 Enclosed Combustor II.A.7 Pit Tank Maximum Total Capacity: 200 barrels combined II.A.8 Pneumatic Controllers Low Bleed Devices Maximum Quantity: 25 II.A.9 Truck Loading Operations Submerged loading II.A.10 Miscellaneous Storage Tanks Storage of motor oil, methanol, glycol, etc Maximum Total Capacity: 1,000 gallons combined Status: In Compliance. II.B Requirements and Limitations II.B.1 Site-Wide Requirements. II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any stationary point or fugitive emission source on site to exceed 10 percent opacity. [R307-401-8] Status: In Compliance. No visible emissions were detected. II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3] Status: In Compliance. UDAQ used the EPA method 9 II.B.1.b The owner/operator shall only use natural gas as fuel in the pump-jack engines, boilers and heaters on site. [R307-401-8] Status: In Compliance. Natural gas is the only fuel used. II.B.2 Tank Requirements. II.B.2.a The owner/operator shall not produce more than 120,000 barrels (1 barrel = 42 gallons) of crude oil per rolling 12-month period. [R307-401-8] Status: In Compliance. 2,561 BBLs of crude were produced in the preceding 12-month period. 4 II.B.2.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the twentieth day of each month using the most recent 12 months of production data reported to the Utah Division of Oil, Gas and Mining. Records of crude oil production shall be kept for all periods when the plant is in operation. Crude oil production shall be determined by process flow meters and/or sales records. [R307-401-8] Status: In Compliance. II.B.2.b At least once each month, the owner/operator shall inspect each closed vent system (including tank openings, thief hatches, and bypass devices) for defects that could result in air emissions according to 40 CFR 60.5416a(c). Records of inspections shall include the date of the inspection and the results of the inspection. [R307-401-8, 40 CFR 60 Subpart OOOOa] Status: In Compliance. The operator supplied inspection forms for review. These inspections were conducted monthly as required by 40 CFR (60) OOOO and this requirement. II.B.2.c The owner/operator shall keep the storage tank thief hatches closed with a weighted mechanism or equivalent, to ensure that the lid remains properly seated, except during tank unloading or other maintenance activities. [R307-401-8] Status: In Compliance. All hatches were found closed at the start of the evaluation. II.B.2.d The owner/operator shall inspect the thief hatches at least once every three months to ensure the thief hatches are closed, latched, and the associated gaskets, if any, are in good working condition. Records of thief hatch inspections shall include the date of the inspection and the status of the thief hatches. [R307-501] Status: In Compliance. The operator supplied inspection forms for review. These inspections were conducted monthly as required by 40 CFR (60) OOOOa and this requirement. II.B.3 Pump-Jack Engine Requirements II.B.3.a Regardless of construction, reconstruction, or modification date, each stationary engine with a maximum engine power greater than 25 hp and less than 100 hp shall comply with 40 CFR 60.4233(d), 40 CFR 60.4233(h), 40 CFR 60.4243(b), 40 CFR 60.4243(e), 40 CFR 60.4243(f), and 40 CFR 60.4245. [40 CFR 60 Subpart JJJJ, R307-401-8] Status: In Compliance. These engines are Arrow Model C101 and are less than 25hp II.B.3.b Regardless of construction, reconstruction, or modification date, each stationary engine with a maximum engine power less than or equal to 25 hp on site shall comply with 40 CFR 60.4233(f)(1), 40 CFR 60.4243(c), 40 CFR 60.4243(e), and 40 CFR 60.4245. [40 CFR 60 Subpart JJJJ, R307-401-8] Status: In Compliance. These engines are maintained according to the manufacturer's suggested schedules. II.B.4 Leak Detection and Repair Requirements II.B.4.a The owner/operator shall conduct a leak detection inspection for each valve(s), flange(s) or other connection, pump(s), compressor(s), pressure relief device(s) or other vent(s), process drain(s), open-ended valve(s), pump seal(s), compressor seal(s), and access door seal(s) or other seal containing or contacting a process stream with hydrocarbons that is associated with each of the approved emission units listed in Section II: Special Provisions. 5 Leak detection inspections shall be conducted according to the following schedule: A. No later than 180 days from the date of this AO. B. At least once every 12 months after the initial leak detection inspection. [R307-401-8] Status: In Compliance. The operator supplied LDAR inspection forms for review. These inspections were conducted twice a year, no sooner than 4 months apart and no later than seven months apart as required by 40 CFR (60) OOOO in excess of this requirement. II.B.4.b Inspections shall be conducted in one of two ways; 1. An analyzer that meets U.S. EPA Method 21, 40 CFR Part 60, Appendix A 2. An optical gas imaging instrument as defined in 40 CFR 60.18(g)(4) The optical gas imaging instrument must meet requirements specified in 40 CFR 60.18(i)(3). Any emissions detected with an optical gas imaging instrument shall be considered a leak in need of repair unless the owner/operator evaluates the leak with an analyzer meeting U.S. EPA Method 21, 40 CFR Part 60 and the analyzer reading is less than 500 ppmv. A reading of 500 ppmv or greater shall be considered a leak in need of repair. Emissions detected from tank gauging, load-out operations, venting of pneumatics, properly operating pressure relief valves, or other maintenance activities shall not be considered leaks. [R307-401-8] Status: In Compliance. The operator uses a Flir GF 320 OGI camera. II.B.4.c The owner/operator is exempt from inspecting a valve, flange or other connection, pump or compressor, pressure relief device, process drain, open-ended valve, pump or compressor seal system degassing vent, accumulator vessel vent, agitator seal, or access door seal under any of the following circumstances: A. The contacting process stream only contains glycol, amine, methanol, or produced water. B. Monitoring could not occur without elevating the monitoring personnel more than six feet above a supported surface or without the assistance of a wheeled scissor-lift or hydraulic type scaffold. C. Monitoring could not occur without exposing monitoring personnel to an immediate danger as a consequence of completing monitoring. D. The item to be inspected is buried, insulated in a manner that prevents access to the components by a monitor probe, or obstructed by equipment or piping that prevents access to the components by a monitor probe. [R307-401-8] Status: In Compliance. 6 II.B.4.d If a leak is detected at any time, the owner/operator shall attempt to repair the leak no later than 5 calendar days after detection. Repair of the leak shall be completed no later than 15 calendar days after detection, unless parts are unavailable or unless repair is technically infeasible without a shutdown. The owner/operator shall inspect the repaired leak no later than 15 calendar days after the leak was repaired to verify that it is no longer leaking. If replacement parts are unavailable, the replacement parts must be ordered no later than 5 calendar days after detection, and the leak must be repaired no later than 15 calendar days after receipt of the replacement parts. If repair is technically infeasible without a shutdown, the leak must be repaired by the end of the next shutdown. If a shutdown is required to repair a leak, the shutdown must occur no later than 6 months after the detection of the leak unless the owner/operator demonstrates that emissions generated from the shutdown are greater than the fugitive emissions likely to result from delay of repair. [R307-401-8] Status: In Compliance. During the April 2022 survey of this source, a leaking hatch was found on the produced water tank and was repaired and verified as required. II.B.4.e Records of inspections and leak detection and repair shall include the following: A. The date of the inspection B. The name of the person conducting the inspection C. Any component not exempt under II.B.4.c that is not inspected and the reason it was not inspected D. The identification of any component that was determined to be leaking E. All records shall be maintained for optical gas imaging instrument as per 40 CFR 60.18(i)(4)(vi) F. The date of first attempt to repair the leaking component G. Any component with a delayed repair H. The reason for a delayed repair 1. For unavailable parts: i. The date of ordering a replacement component ii. The date the replacement component was received 2. For a shutdown: i. The reason the repair is technically infeasible ii. The date of the shutdown iii. Emission estimates of the shutdown and the repair if the delay is longer than 6 months I. Corrective action taken J. The date corrective action was completed K. The date the component was verified to no longer be leaking 7 L. The records of each component exempt under II.B.4.c 1. Type of component 2. Description of qualifying exemption [R307-401-8] Status: In Compliance. The records supplied by the operator met the standards required here. II.B.5 Combustor Requirements II.B.5.a All exhaust gas/vapors from the oil storage tanks shall be routed to the operating combustor. [R307-401-8] Status: In Compliance. Tank emissions are routed to an enclosed combustor. II.B.5.b The combustor shall operate with a continuous pilot flame and an auto-igniter. [R307-503-4] Status: In Compliance. These components are installed. II.B.5.c The combustor shall operate with no visible emissions. [R307-401-8] Status: In Compliance. No visible emissions were detected. II.B.5.c.1 Visual determination of smoke emissions from flares shall be conducted according to 40 CFR 60, Appendix A, Method 22. [R307-401-8] Status: In Compliance. The operator indicated on the monthly inspection records that they use the EPA method 22. Section III: APPLICABLE FEDERAL REQUIREMENTS In addition to the requirements of this AO, all applicable provisions of the following federal programs have been found to apply to this installation. This AO in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including UAC R307. NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines Status: In Compliance. The engines installed are Arrow C-101 and are EPA certified and less than 25 hp. NSPS (Part 60) OOOOa: Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015 Status: In Compliance. This source has an Approval Order from the State of Utah with legal and enforceable limits. This source is exempt from OOOOa for the collection of fugitive emissions components. A monitoring, repair, and record keeping program is in place that would satisfy the requirements of 40 CFR (60) OOOOa for the collection of fugitive emissions components, closed vent system, and storage vessel facilities. See above evaluations. There are currently no affected facilities installed. This would include the storage tank battery as there is not enough production to meet the PTE for an affected facility. 8 MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: In Compliance. Applicable parts of this standard are met with compliance with JJJJ. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Oil and Gas Industry: General Provisions [R307-501] Status: In Compliance. There are no general provisions that exceed the conditions already imposed by the Approval Order. See the evaluation in Section I above. Oil and Gas Industry: Pneumatic Controllers. [R307-502] Status: In Compliance. This source does not use continuous bleed natural gas-driven pneumatic controllers as described in 40 CFR 60.5365(d)(1). Oil and Gas Industry: Tank Truck Loading [R307-504] Status: In Compliance. The truck loading area is suitable for submerged loading and it is routine for truck drivers to load this way. This source is currently exempt from the installation of a vapor capture line by registration with an Approval Order. Oil and Gas Industry: Flares. [R307-503] Status: In Compliance. The combustor has a lit pilot with an auto-ignition device and has been upgraded with a pressure regulating valve. PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. Last year’s inspection found some items of noncompliance but no enforcement action was taken. Those conditions were not found during this year’s evaluation. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN156210001-16, dated October 25, 2016: In Compliance - This source was found to be clean and well-kept with no visible or fugitive emissions. The source was inspected by AVO and with an OGI camera and found to be free of leaks. The operator's representatives were pleasant and cooperative. Requested records were provided in a timely manner and reviewed at the local field office. HPV STATUS: Not Applicable. 9 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 remain as planned. The DAQ was joined by Berry personnel during the site inspection. ATTACHMENTS: None