DAQ-2024-011514

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DAQC-PBR156350001-24
Site ID 15635 (B1)
MEMORANDUM

TO: FILE – BERRY PETROLEUM COMPANY, LLC – LC TRIBAL 04-27D-56

THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Manager

FROM: Fred Goodrich, Environmental Scientist

DATE: August 19, 2024

SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION

INSPECTION DATE: June 12, 2024

SOURCE LOCATION: LC TRIBAL 04-27D-56
Lat: 40.023968 Long: -110.553182

Business Office:
11117 River Run Boulevard
Bakersfield, CA 93311

SOURCE TYPE: Tank Battery
Duchesne County
API: 4301350262

SOURCE CONTACTS: Jon Armstrong, Corporate Environmental Contact
Phone: [phone], Email: [e-mail]
Matt Guest, Local Contact
Email: [e-mail]

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.

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SOURCE EVALUATION: Site Type: PBR-Uncontrolled
No Flare Controls
Site powered by Engine
DOGM current 12 month rolling production is: 2,279 BBLs.
Utah Statute R307-506 requires a source with throughput
greater than 8,000 BBLs to have controls.

REGISTERED EQUIPMENT: Engine - No info provided
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 as described in 40 CFR 60.5365(d)(1). Oil and Gas Industry Registration Requirement The source is registered with the DAQ. [R307-505-3(3)] In Compliance. 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. Storage Vessels Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. All hatches were found closed at the start of the evaluation. 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. 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. The recordkeeping procedures of Berry Petroleum are found to be orderly and complete. These records were reviewed at the local office.

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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 engines are all Arrow model C-101 engines and exempt from this subpart. 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 detected. Emission Inventory: An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. Berry submitted for the 2020 emissions inventory. Applicable Federal Regulations: 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. 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. There are no longer any affected facilities installed. This source no longer meets the production threshold for controls and a LDAR requirement. NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. In Compliance. Most of the engines at this source have been performance tested and the emissions were within the limits allowed in this subpart. The recordkeeping and maintenance provisions are also met. See above evaluations. Some engines records were not observed.

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PREVIOUS ENFORCEMENT
ACTIONS: The DAQ issued a Compliance Advisory and Warning Letter in
2023 in response to finding a blowdown valve had been left
open.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to: LC TRIBAL 04-27D-56: 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