DAQ-2024-011948

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DAQC-CI155960001-24
Site ID 15596 (B1)
MEMORANDUM

TO: FILE – BERRY PETROLEUM COMPANY, LLC – LC DLB 12-15-56

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

FROM: Fred Goodrich, Environmental Scientist

DATE: June 20, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Duchesne County

INSPECTION DATE: June 19, 2024

SOURCE LOCATION: Lat 40.0446, Lon -110.553223
Rural Duchesne County
Business Office:
11117 River Run Boulevard
Bakersfield, CA 93311

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 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-AN155960002-18, dated January
3, 2018

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Berry Petroleum Company, LLC - LC DLB 12-15-56
11117 River Run Boulevard NW SW ¼ Sec 15 T5S R6W UBSM
Bakersfield, CA 93311 Duchesne County

SIC Code: 1311: (Crude Petroleum & Natural Gas)

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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. The DAQ did not identify any modifications or unauthorized
equipment.
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. All requested records were observed at Berry Petroleum field office.
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 DAQ found all of the installed equipment to be clean and
maintained in good repair. The pollution control system components appear to be operated as expected.

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.
I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18] Status: In Compliance. Location has been built and in production status for several years.

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Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 LC DLB 12-15-56 Production Tank Battery
II.A.2 Engines Maximum Site-Wide Rating: 130 hp combined Maximum Single Engine Rating: 65 hp Fuel: Natural Gas
II.A.3 Boilers & Heaters Includes: heater treaters, separators, and tank heaters Maximum Total Capacity: less than 5.0 MMBtu/hr each Fuel: Natural Gas
II.A.4 Oil Storage Tanks Maximum Total Capacity: 1,600 barrels combined
II.A.5 Produced Water Storage Tanks Maximum Total Capacity: 800 barrels combined
II.A.6 Pit Tank Maximum Total Capacity: 200 barrels
II.A.7 One (1) Combustor
II.A.8 Pneumatic Controllers Low Bleed Devices Maximum Quantity: 25
II.A.9 Truck Loading Operations Control: Vapor Capture Line
II.A.10 Miscellaneous Storage Tanks Storage of motor oil, methanol, glycol, etc. Maximum Total Capacity: 500 gallons each
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: Out of Compliance. Pump Jack engine Arrow L-795 was observed with 15% opacity reading. 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. Conducted under Method 9 observation.

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II.B.2 Storage Tank (Storage Vessel) Requirements II.B.2.a The owner/operator shall not produce more than 50,000 barrels (1 barrel = 42 gallons) of crude oil per rolling 12-month period. [R307-401-8] Status: In Compliance. A search of DOGM records found 4,835 BBLs of crude were produced in the preceding 12-month period. II.B.2.a.1 The owner/operator shall: A. Use the monthly production data reported to the Utah Division of Oil, Gas, and Mining to calculate a new 12-month total by the twentieth day of each month using data from the previous 12 months. B. Determine crude oil production with process flow meters and/or sales records. C. Keep the production records for all periods the plant is in operation. D. Record crude oil production on a daily basis. [R307-401-8] Status: In Compliance. Records verified. II.B.2.b At all times after startup of production, the owner/operator shall route all gases, vapors, and fumes from the oil storage tanks on site to the operating combustor. [R307-401-8] Status: In Compliance. All tanks in the battery have their vent lines gathered to the combustor. II.B.2.c The owner/operator shall keep the storage tank thief hatches and other tank openings closed and sealed 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 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. II.B.3 Truck Loading II.B.3.a The owner/operator shall load the tanker trucks on site by the use of submerged loading. [R307-401-8, R307-504-4] Status: In Compliance. The truck loading area is suitable for submerged loading and it is routine for truck drivers to load this way. II.B.3.b The owner/operator shall connect a vapor capture line to the operating combustor for use during on-site truck loading operations. The vapor capture line shall be used at all times during loading operations. [R307-401-8] Status: In Compliance. This source is currently exempt from the installation of a vapor capture line by registration with an Approval Order.

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II.B.4 Combustor Requirements II.B.4.a Each combustor shall operate with a continuous pilot flame and be equipped with an auto-igniter. [R307-503-4] Status: In Compliance. The flare has a continuously lit pilot and auto-ignition capability. II.B.4.b Each combustor shall operate with no visible emissions. [R307-401-8] Status: In Compliance. No visible emissions were detected. II.B.4.b.1 Visual determination of emissions from each combustor 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. II.B.5 Engine Requirements II.B.5.a The owner/operator shall comply with the emission standards listed in 40 CFR 60.4233 for each stationary engine on site, regardless of the engine's construction, reconstruction, or modification date. To determine the applicable emission standards, the owner/operator shall use the date of this AO for the manufacturer date of the engine. [40 CFR 60 Subpart JJJJ, R307-401-8] Status: In Compliance. Recordkeeping retention requirements of the performance testing have expired. II.B.5.a.1 To demonstrate compliance with the above condition, the owner/operator shall either: A. Purchase a Certified Stationary Internal Combustion Engine as defined in 40 CFR 60.4248, or B. Conduct an initial performance test according to 40 CFR 60.4244 [40 CFR 60 Subpart JJJJ, R307-401-8] Status: In Compliance. An Arrow L 795 is not certified but may have been performance tested. A maintenance plan is followed that will maintain compliance of a non-certified engine. II.B.5.a.2 For each engine on site, the owner/operator shall maintain records of engine certification or the initial performance test. [40 CFR 60 Subpart JJJJ, R307-401-8] Status: In Compliance. Recordkeeping requirements of performance testing have expired.

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II.B.6 Monitoring Requirements of Fugitive Emissions (Leak Detection and Repair) II.B.6.a The owner/operator shall develop a fugitive emissions monitoring plan. At a minimum, the plan shall include: A. Monitoring frequency B. Monitoring technique and equipment C. Procedures and timeframes for identifying and repairing leaks D. Recordkeeping practices E. Calibration and maintenance procedures [R307-401-8] Status: In Compliance. A site wide plan was developed by the operator and complies with these requirements. II.B.6.a.1 The plan shall address monitoring for "difficult-to-monitor" and "unsafe-to-monitor" components. [R307-401-8] Status: In Compliance. Requirement consistent with the Emissions Monitoring Plan required for compliance with NSPS (60) OOOO. II.B.6.b The owner/operator shall conduct monitoring surveys on site to observe each "fugitive emissions component" for "fugitive emissions." A. "Fugitive emissions component" means any component that has the potential to emit fugitive emissions of VOC, including but not limited to valves, connectors, pressure relief devices, open-ended lines, flanges, covers and closed vent systems, thief hatches or other openings, compressors, instruments, and meters. B. "Fugitive emissions" are considered any visible emissions observed using optical gas imaging or a Method 21 instrument reading of 500 ppm or greater. [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 7 months apart as required by 40 CFR (60) OOOO in excess of this requirement. II.B.6.b.1 Monitoring surveys shall be conducted according to the following schedule: A. No later than 60 days after startup of production, as defined in 40 CFR 60.5430a. B. Semiannually after the initial monitoring survey. Consecutive semiannual monitoring surveys shall be conducted at least 4 months apart. C. Annually after the initial monitoring survey for "difficult-to-monitor" components. D. As required by the owner/operator's monitoring plan for "unsafe-to-monitor" components. [R307-401-8] Status: In Compliance. The records supplied by the operator met the standards required here.
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II.B.6.b.2 Monitoring surveys shall be conducted using one or both of the following to detect fugitive emissions: A. Optical gas imaging (OGI) equipment. OGI equipment shall be capable of imaging gases in the spectral range for the compound of highest concentration in the potential fugitive emissions. B. Monitoring equipment that meets U.S. EPA Method 21, 40 CFR Part 60, Appendix A. [R307-401-8] Status: In Compliance. The operator uses a Flir GF 320 OGI camera. II.B.6.c If fugitive emissions are detected at any time, the owner/operator shall repair the fugitive emissions component as soon as possible but no later than 15 calendar days after detection. If the repair or replacement is technically infeasible, would require a vent blowdown, a well shutdown or well shut-in, or would be unsafe to repair during operation of the unit, the repair or replacement must be completed during the next well shutdown, well shut-in, after an unscheduled, planned or emergency vent blowdown or within 24 months, whichever is earlier. [R307-401-8] Status: In Compliance. The supplied inspection forms showed that the latest surveys did not find any leaks. II.B.6.c.1 The owner/operator shall resurvey the repaired or replaced fugitive emissions component no later than 30 calendar days after the fugitive emissions component was repaired. [R307-401-8] Status: In Compliance. The supplied inspection forms showed that the latest surveys did not find any leaks. II.B.6.d The owner/operator shall maintain records of the fugitive emissions monitoring plan, monitoring surveys, repairs, and resurveys. [R307-401-8] Status: In Compliance. Records were observed at local field office.

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) 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 an 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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AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

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.

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN155960002-18,
dated January 3, 2018: This source was found to be clean and
well-kept with no fugitive emissions. The source was inspected
by AVO and with an OGI camera and found to be free of leaks.
The DAQ found visible emissions from Pump Jack (Arrow
L-795) engine with a 15% opacity reading. The operator's
representatives were pleasant and cooperative. Requested
records were provided in a timely manner and reviewed at the
local field office. Berry personnel reported within one week that
the engine had its connecting rod packing replaced and pistons
re-ringed. Due in part to the recent joint NOV with the USEPA,
the DAQ recommends no enforcement action (NICNAR) taken
for the issue of the smoking pump jack engine.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: The DAQ recommends frequency of inspections to be increased
from regular scheduled inspections.

NSR RECOMMENDATIONS: None

ATTACHMENTS: None