Document 158pXa6QxYOz6OLozdZObkkvm
Steamboat Butte E5 Tank Battery Wind River Energy Commission Wind River Reservation, Fremont County
Full Compliance Evaluation (FCE) Clean Air Act
Inspection Date:
July 24, 2024
Inspection Report Date:
December 4, 2024
EPA Representative:
Robert (Bob) Gallagher, EPA - Region 8
Tribal Representatives:
Dean Goggles (Northern Arapaho), (307) 438-2163
Company Representatives:
Wind River Energy Commission and their Subcontractor MI3 Petroleum Engineering x Ed Pearson, Director of Operations (via Zoom) x Justin Lajeunesse, Production Superintendent x John Kennah, Team Lead
Inspection Report Prepared By: Robert (Bob) Gallagher
Inspection Report Reviewed By: Last CAA Inspection:
Scott Patefield August 7, 2019
Digitally signed by SCOTT
SCOTT PATEFIELD PATEFIELD
Date: 2024.12.04 14:06:13 -07'00'
Applicable Rules:
Tribal Minor NSR Permit Application NSPS Subpart OOOO
CAA Permit History: Part 49 Permit Number: SMNSR-WR-000005-2017.002 Part 49 Permit Number: SMNSR-WR-000005-2020.003
Issue Date: January 22, 2019 Issue Date: October 2, 2020
ICIS Facility ID: SIC Code:
AIR08000005601300001 1311 - Crude Petroleum and Natural Gas
Reservation: Tribes:
Wind River Reservation Northern Arapaho and Eastern Shoshone
General Source Information
Parent Company Name:
Wind River Energy Commission (WREC)
Plant Name:
Steamboat Butte E5 Tank Battery
Plant Mailing Address:
PO Box 538 Ft. Washakie, Wyoming 82514
On-site Office:
14567 Highway 287 Ft. Washakie, Wyoming 82514
Plant Location:
Latitude Longitude
43.26592 N -108.90416 W
County, State:
Fremont, Wyoming
Responsible Official:
Ed Pearson
Overall Inspection Findings
The WREC facility was operational during the inspection. There were numerous areas of concern noted during the inspection. Also, no compliance assistance was provided during the inspection, however, this inspection report will be provided to WREC upon finalization.
The following areas of concern were noted during the inspection, including;
x annual emissions and annual fees that were due in 2023 and 2024 were not submitted (Condition I.H.1)
x since January of 2023, no monthly inspections were conducted on the flares, on the tank covers, or closed vent systems (Condition I.E.2(a))
x the flares were not equipped with monitoring systems (Condition I.D.4) x permit application for new ownership had not been submitted to EPA
Enforcement History
No previous enforcement actions were found in the ICIS database.
Description of Process
The Steamboat Butte E5 tank battery operates continuously 8,760 hours per year. It handles 800 barrels per day of crude oil, 35,000 barrels of produced water, and 0.144 MMscfd of gas which may contain up to 5.00% of H2S.
Production from the wells enters the facility through two inlet free water knockouts (FWKO). From the FWKOs, oil is sent to the bulk treater (ES HT-1) for secondary separation of the gas, oil, and produced water. Produced water from the FWKOs and bulk treater is sent to two
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1,500-barrel storage tanks (E5 WTK-01 & E5 WTK-02) and then is either routed to water injection wells or trucked to offsite surface water discharge ponds. Produced gas is routed to the process flare (FL-1).Vapors from the two produced water tanks are vented to atmosphere.
All oil exiting the bulk treater is routed to 500-barrel Run Tanks (E5 Run Tank) and then released for custody transfer via a LACT unit. During abnormal operating conditions, reject or overflow oil is directed to either Reject Tank (E5 Reject Tank) or Overflow Tank (E5 Reject Tank).
Vapors from the crude oil tank, overflow tank, and reject tank are controlled by the tank flare (FL-2). Gas flashed off the bulk treater is routed to the process flare (FL-1). Vapors from the produced water tanks are vented to atmosphere.
Additionally, one pop & rupture tank is used to store liquids from the FWKOs during upset conditions. These tanks vent to atmosphere.
Equipment List
Equipment ID
FL-1 FL-2 E5HT-1 E5 Run Tank E5 Overflow Tank E5 Reject Tank E5WTK-01 E5WTK-02 E5 Drip Tank E5 PR Tank E5B-1 E5 LOAD FUG-1 MSS-DEGAS
Summary of Equipment
Equipment Description
Process Flare (1996) Tank Flare (1996) E5 Bulk Treater E5 Crude Oil Run Tank E5 Crude Oil Overflow Tank E5 Crude Oil Reject Tank E5 Produced Water Tank #1 E5 Produced Water Tank #2 E5 Flare Knockout Tank E5 Pop & Rupture Tank E5 Bulk Treater E5 Drip Tank Truck Loading Process Fugitives Tank Degassing
Capacity / Design Rate
Control ID
292 bbl 500 bbl 500 bbl 500 bbl 1,500 bbl 1,500 bbl 606 bbl 1,000 bbl 2.7 MMBTU/hr
FL-1 FL-2 FL-2 FL-2 None None None None None None None None
General Inspection Observations and Commentary
Dean Goggles and I arrived at the WREC Office at 9:10 a.m. Upon arrival at the facility, we met with representatives of the subcontractor MI3 Petroleum Engineering, Ed Pearson, Director of Operations (via Zoom), Justin Lajeunesse, the Production Superintendent, and John Kennah, the Team Lead at Steamboat Butte E5 Tank Battery. Departure time was approximately 11:10 a.m.
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Opening Meeting The EPA and Tribal staff were given a short safety meeting to ensure proper PPE was worn and exit procedures in the event of an emergency. We observed some of the records that were available at the site, including production numbers at E5, which were within the permit limits for the rolling 12-month. Walk Through Inspection Observations We traveled to the Steamboat Butte E5 Tank Battery where we observed the two flares (production and tank) operating with no visible emissions at the Tank Battery (see Attachment). Observations were made of all the following emission sources listed. Records Review/Closing Meeting WREC provided some of the requested records for our review, but could not provide monthly flare observations, annual emissions calculations, and fee calculations since taking ownership in January 2023.
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Uncontrolled Potential to Emit (PTE) Proposed Allowable Emission Rates
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Permit History
Ownership Change
Marathon Oil Company sold the facility to Merit Energy effective December 1, 2016. WREC took ownership of the facility starting on January 1, 2023.
Tribal Minor Source Permit Application
WREC (newest owner) had not submitted a Tribal New Source Review Permit application for the Steamboat Butte operations to update the ownership. The previous application submitted by Merit Energy in November of 2018 requested:
x Issuance of synthetic minor permit x E5 facilities are registered in tribal permit rule x Separation of facilities to separate permitted sources x Federally enforceable limits on 2 flares
With the flares as enforceable control devices under NSPS - OOOO and based on physical properties of the produced oil and facility production limitations, the emissions are as follows:
VOC
SO2
H2S
Uncontrolled PTE, tpy
629
0
128
Controlled PTE, tpy
27
228
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*See the following NSPS - OOOO conditions
Synthetic Minor Source Permit # SMNSR-WR-000005 Issued - January 22, 2019 and October 2, 2020
Review of Minor New Source Review (MNSR) Permit Provisions
I.C.1 Facility-Wide Emissions Limitations (a) Annual facility crude oil throughput shall not exceed 292,000 barrels (bbls) of oil per year. (b) Annual facility produced water throughput shall not exceed 12,775,000 bbls of produced water per year. (c) The volume of gas combusted by the process flare shall not exceed 44.165 million standard cubic feet per year. (d) The volume of gas combusted by the tank flare shall not exceed 4.748 million standard cubic feet per year. (e) Produced gas H2S content shall not exceed 50,000 parts per million (ppm) H2S by volume.
OBSERVATION: Records were observed on-site and monthly numbers had been recorded that would estimate annual emissions below the limits.
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Month E5 Oil Production
E5 Process Flare Volume
Rolling 12-month
Rolling 12-month total
total (bbls)
(mscf)
Jul-24
114,332
24,224
Jun-24
113,696
22,608
May-24
111,551
19,987
Apr-24
111,336
17,141
Mar-24
110,836
16,158
Feb-24
110,991
13,967
Jan-24
112,841
12,841
Dec-23
114,922
13,244
Nov-23
115,854
13,493*
Oct-23
117,199
15,408*
Sep-23
118,733
19,332*
Aug-23
118,563
19,416*
Jul-23
117,873
15,576*
Jun-23
118,504
12*
May-23
121,854
396*
Apr-23
120,972
24,224*
Mar-23
122,827
12,324*
Feb-23
123,017
12,324*
Jan-23
107,993
13,039*
*total is based on 12 times the monthly production since records were unavailable for months
prior to the facility being acquired by WREC
I.D.1 Requirements for the Separator (a) The Permittee shall install and operate no more than one 292 bbl bulk heater treater separator (separator) equipped with no more than one heater limited to a maximum heat input capacity of 2.7 million British thermal units per hour (MMBtu/hr).
OBSERVATION: The number of heater treater separators on-site were verified to correspond with the number and size allowed in the permit.
I.D.2 Requirements for the Crude Oil and Produced Water Storage Tanks (a) The Permittee shall install, operate and maintain no more than: one (1) 500 bbl Run Tank used to store crude oil; one (1) 500 bbl reject oil tank used to store rejected oil that does not meet specifications for custody transfer; one (1) 500 bbl oil overflow tank used to store overflow oil when the Run Tank fills to capacity; and two (2) storage tanks used to store produced water, each limited to a maximum storage capacity of 1,500 bbls.
OBSERVATION: The five tanks on-site was verified to correspond with the number allowed in the permit.
I.D.3 Requirements for Closed-Vent Systems: The Permittee shall design, install, continuously operate and maintain closed-vent systems.
OBSERVATION: The closed-vent system was verified to correspond with what is allowed in the permit and no emissions were observed.
I.D.4
Requirements for the Flares (a) The Permittee shall design, install, continuously operate and maintain the
process flare and tank flare such that the mass content of the uncontrolled VOC emissions from the separator and the crude oil tanks are reduced by at
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least 95.0% by volume. (b) The Permittee shall ensure that each flare is designed and operated in
accordance with the requirements of 40 CFR 60.18(b) for flares, unless otherwise specified in this permit. (c) The Permittee shall ensure that each flare is: (i) Operated properly per the manufacturer, vendor or Permittee's written
instructions at all times that produced natural gas, or gases, vapors and fumes are routed to it; (ii) Designed for and operated with no visible smoke emissions, as determined by the methods specified in Condition E.2.(b) of this permit; (iii) Equipped with one of the following: (A) A continuous burning pilot flame, a thermocouple and a
malfunction alarm and notification system if the pilot flame fails; or (B) An operational electronically controlled automatic ignition device that sparks on a continuous cycle; and (iv) Equipped with a monitoring system for continuous measuring and recording of the parameters that indicate proper operation of the flare and the continuous burning pilot flame or electronically controlled automatic ignition device (such as a chart recorder, data logger or similar device). Where sufficient to meet the monitoring requirements in this permit, the Permittee may use a Supervisory Control and Data Acquisition (SCADA) system to monitor and record the required data. OBSERVATION: Flares were observed to be burning with no visible emissions during the on-site inspection. The flares were not equipped with monitoring systems.
I.E.1 Testing and Monitoring for Facility Wide Emission Limitations OBSERVATION: The facility had the flow monitoring devices to measure production numbers to stay within the limits at the site.
I.E.2 Flares and Closed-Vent Systems (a) The Permittee shall at a minimum perform monthly inspections of the flares and closed-vent systems as follows: (i) Inspect the thermocouple and the malfunction alarm and notification system if the pilot flame fails or the electronically controlled automatic ignition device, as applicable, to ensure proper operation; (ii) Perform an auditory, visual, olfactory (AVO) inspection of the closedvent systems to ensure proper condition and functioning; (iii) Inspect the parameter monitoring system and recorded measurements to ensure proper operation of the flare and monitoring system; and (iv) Respond to any malfunction alarm or other indication of improper flare, closed-vent system or monitoring system operation by following the manufacturer's, vendor's, or Permittee's instructions to identify the cause of the deficiency and make any necessary repairs within 30 days
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of identifying the deficient condition to return the flare and monitoring system to compliant operation. All repairs and maintenance activities shall be recorded in a maintenance and repair log and shall be made available for inspection. (b) The Permittee shall at a minimum perform monthly visual inspections of the flares to ensure they operate with no visible smoke emissions. If any visible smoke emissions are detected during the monthly inspection or any other time, the Permittee shall take the following actions: (i) The Permittee shall demonstrate that the flare operates with no visible emissions, except for periods not to exceed a total of 5 minutes during any 2 consecutive hours, using the procedures specified in EPA Method 22 at 40 CFR part 60, appendix A. The observation period shall be 2 hours; (ii) If the flare fails the visual emissions test, the Permittee shall follow the manufacturer's, vendor's, or Permittee's repair instructions to return the flare to compliant operation. All repairs and maintenance activities shall be recorded in a maintenance and repair log and shall be made available for inspection; (iii) Upon return to operation from any repair and maintenance activity, the flare shall pass a Method 22 test; and (iv) If the flare fails a follow up Method 22 test, the Permittee shall repeat the procedures in paragraphs (i) through (iii) of this section, until the flare passes a follow up test. OBSERVATION: Facility had no recent monthly inspections documented at the site.
I.F. Recordkeeping Requirements OBSERVATION: The facility had the recordkeeping required by the permit at the site.
I.G. Requirements for Records Retention OBSERVATION: The facility had been following the requirements for records retention.
I.H.1 Requirements for Reporting - Annual Compliance Reports OBSERVATION: The facility had not submitted the annual compliance reports for 2022 and 2023.
New Source Performance Standards
*Subpart OOOO - Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution [40 CFR 60.5360 - 60.5499] 60.5413 What are the performance testing procedures for control devices used to demonstrate compliance at my storage vessel or centrifugal compressor affected facility? This section applies to the performance testing of control devices used to demonstrate compliance with the emissions standards for your centrifugal compressor affected facility. You must demonstrate that a control device achieves the performance requirements of
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60.5412(a) using the performance test methods and procedures specified in this section. For condensers, you may use a design analysis as specified in paragraph (c) of this section in lieu of complying with paragraph (b) of this section. In addition, this section contains the requirements for enclosed combustion device performance tests conducted by the manufacturer applicable to both storage vessel and centrifugal compressor affected facilities. (a) Performance test exemptions. You are exempt from the requirements to conduct performance tests and design analyses if you use any of the control devices described in paragraphs (a)(1) through (7) of this section.
(1) A flare that is designed and operated in accordance with 60.18(b). You must conduct the compliance determination using Method 22 at 40 CFR part 60, appendix A-7, to determine visible emissions. OBSERVATION: Net Heating Values and Tip Velocity values were demonstrated to be in compliance. Attachment Photo Log
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Date 7/24/2024 7/24/2024 7/24/2024 7/24/2024
Time 10:54 AM 10:54 AM 10:55 AM 10:55 AM
Attachment Photo Log
Location
Steamboat Butte E5 Tank Battery Steamboat Butte E5 Tank Battery Steamboat Butte E5 Tank Battery Steamboat Butte E5 Tank Battery
File ID P1030833 .jpg P1030834 .jpg P1030835 .jpg P1030836 .jpg
Description Water Tanks Production Tanks Heater Treater
Flare
Photo of Water Tanks 11
Photo of Production Tanks
Photo of the Heater Treater 12
Photo of the Flare 13