Document x1zgQEdYgV6pqaKEM4voykB0J

EOG Resources, Clarks Creek Central Facility Evaluation (FCE) On-Site Clean Air Act (CAA) Inspections Inspection Date: August 19, 2021 Inspection Report Date: October 19, 2021 EPA Representatives: Alexis North & Mike Stovern Company Representatives: None Inspection Report Prepared By: Alexis North Inspection Report Reviewed By: Last CAA Inspection: Scott Patefield None Digitally signed by Patefield, Patefield, Scott Scott Date: 2021.10.19 15:32:38 -06'00' Applicable Rules: CAA Title V Operating Permitting (Part 71 operating permit) V-TAT-000820-2018.00 (issued 1/22/2020) 40 C.F.R. Part 60, Subpart JJJJ--Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (NSPS JJJJ) 40 C.F.R. Part 60, Subpart OOOOa--Standards of Performance for Crude Oil and Natural Gas Facilities for Which Construction, Modification or Reconstruction Commenced After September 18, 2015- (NSPS OOOOa) 40 C.F.R. Part 63, Subpart HH--National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities (MACT HH) 40 C.F.R. Part 63, Subpart ZZZZ--National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities (MACT ZZZZ) CAA Permit History: EPA issued the initial Part 71 operating permit on January 22, 2020. Permit Number: V-TAT-0008202018.00. x Tribal Minor NSR Part 1 registration submitted 4/25/2017. x Tribal Minor NSR Part 2 registration submitted 8/11/2017. x Title V initial application submitted 7/27/2018 including 1x 1340 Catepillar G3516 engine, dehy for fuel gas only, 18 oil storage tanks plus 6 water storage tanks, VRUs and two flares for tank emissions. NOx 41.5, VOC 129.2, CO 144.5, HAP 6.8 tons per year each. x Multiple Part 1 and Part updates submitted after Title V application. x Most recent Part 2 registration update 12/10/2019- NOx 100.59, VOC 188.7, CO 192.99 with six (6) engines (4 of 6 use NSPS JJJJ emission limitations in PTE calculation). 1 General Source Information Parent Company Name: Facility Name: Facility Location: EPA Region: County, State: Reservation & Tribe: Responsible Official: SIC Code: ICIS Air ID: EOG Resources, Incorporated (EOG) Clarks Creek Central Facility (Clarks Creek) 47.9059, -102.7554 8 McKenzie County, North Dakota Fort Berthold Indian Reservation & MHA Nation Matthew Oliver 1311 AIR 080000003805300180 Areas of Concern x Title V permit does not currently align with operations. EOG must update their Title V permit to reflect current operations (including but not limited to: engine serial #JFE01145, Cimmaron enclosed combustor for dehy, 34 storage tanks on site versus 24, increased PTE from Title V application). x Emissions with IR camera from enclosed combustor at dehy unit. x Emissions with IR holding together from air assisted flare controlling tank emissions. Compliance Assistance Recommend updating Title V permit to reflect onsite operations ASAP. Recommend investigating fan speeds for air assisted flare showing emissions. Recommend investigating emissions from Cimmaron enclosed combustor at dehy unit. Onsite Inspection Details Arrived onsite at 9:30 am 8/19/2021 and knocked on the door of the main office. Alerted Eric in the office that we were onsite for a Title V inspection and we would be using an IR camera to scan tanks and dehy and would stay out of the engine building. Made notes of storage tank and flare counts, closely looked at dehy piping and counted strokes from the glycol pump (5 strokes in 30 seconds). The dehy is controlled using a Cimmaron (serial 5604315). EPA detected emissions out of the top of the Cimmaron even though pilot light was lit (MOV_2727). No emissions were detected from any of the three storage tank groups (6 tanks on eastern edge as you pull onsite, 24 tanks on s/w corner and 4 tanks on n/w corner nearest Targa facility), all associated flares appeared to be lit with a pilot light and operating. The air assisted flare on the n/w corner nearest Targa facility had emissions holding together (MOV_2726). Departed facility at 10:00 am. EPA sent a follow up email with questions for EOG on September 7, 2021 and EOG responded on September 30, 2021. That email exchange is included in the appendix to this report. While several questions were asked/answered, I'd like to summarize the production throughput and flaring in the body of the report. Essentially, this facility has very high oil production and gas sales and very low (1.1%) gas flaring, see below: Dates of Production June 2021 All of 2020 Oil Produced (bbl) 67,983 1,441,602 Gas Sold (MSCF) 402,274 4,776,814 Gas Flared (MSCF) 291 53,456 2 EOG contact Mathew Oliver, during a call from EPA to EOG on Thursday September 2, 2021, stated the flow of produced natural gas and storage tank emissions to the flares is measured with flow meters. Thus, the gas flared amounts listed above and, in the tables attached in the appendices, are measured not calculated. EOG Clarks Creek currently has 24 wells feeding production to this site with 7 additional wells potentially getting drilled in the future, no pending dates for those as of now. Potential to Emit (PTE) Table below is from the 12/10/19 updated Part 2 registration PTE summary: Cropped out for ease of read: SO 2 = 0.22 tpy, PM = 3.52, Formaldehyde = 6.15 tpy and total HAPs 10.11 tpy making this a minor MACT source. 3 Table below is from the 7/27/2018 Title V application, Table 3 Emissions Summary: Table below is from the 7/27/2018 Title V application, Table 4 HAP Emissions Summary: CAA Title V Operating Permit V-TAT-000820-2018.00 (issued 1/22/2020) Section I. Facility Information and Emission Unit Identification B. Facility Emission Points 4 Table 2: Emissions Units and Emission Generating Activities (with inspection notes added) Unit I.D. DEHY-2 HTR-3 ENG-1 ENG-2 ENG-3 Description TEG Dehydration Unit, 20.0 MMscfd Installed: August 1, 2018 TEG Glycol Reboiler Heater on DEHY-2, 0.6 MMbtu/hr Caterpillar G3516LE, 10.12 MMBtu/hr*, 1340 hp*, 4SLB* Natural Gas-fired Compressor Engine powering an Ariel JGE/4 reciprocating compressor1: Serial Number: WPW00277 Installed: August 11, 2017 Manufactured: June 27, 2006 Ariel Reciprocating Compressor Serial Number: F-13180 Caterpillar G3606 A4 TALE, 14.07 MMBtu/hr*, 1875 hp, 4SLB Natural Gas-fired Compressor Engine powering an Ariel JGD4 reciprocating compressor: Serial Number: JFE00926 Installed: August 1, 2018 Manufactured: February 13, 2018 Ariel Reciprocating Compressor Serial Number: F-55773 Caterpillar G3606 A4 TALE, 14.07 MMBtu/hr*, 1875 hp, 4SLB Natural Gas Engine powering an Ariel JGD4 reciprocating compressor: Serial Number: JFE01058 Installed: August 1, 2018 Manufactured: June 14, 2018 Ariel Reciprocating Compressor Serial Number: F-56960 Control Equipment FL1 None (IEU) None Oxidation Catalyst Oxidation Catalyst Inspection Comments Added Dehy was operating, reboiler hooked up to enclosed combustor not listed here. Some emissions from enclosed combustor (MOV_2727). Listed as gap engine, did not physically verify if this was operating as did not want to enter compressor housing. Noted 3 engines running. Received passing performance tests reports on 10/25/2019 and 10/27/2020. Noted three engines running. Received passing performance tests reports on 10/25/2019 and 10/27/2020. Noted three engines running. 1 The reciprocating compressors have emissions due to fugitive emissions from the rod packing. An emissions unit ID was not provided by the operator solely for the reciprocating compressors and instead will be listed together as emissions units ENG-1, ENG-2 or ENG-3. 5 Unit I.D. TNK1 TNK2 TNK3 TNK4 TNK5 TNK6 TNK7 TNK8 TNK9 TNK10 TNK11 TNK12 TNK13 TNK14 TNK15 TNK16 TNK17 TNK18 Description 18 -- 400 bbl* Condensate/Oil Storage Tanks Serial No. 1006-953 Installed: August 11, 2017 HTR-1 WTR TNK-1 WTR TNK-2 WTR TNK-3 WTR TNK-4 WTR TNK-5 WTR TNK-6 Separator Heater, 2.5 MMBtu/hr Six 400 bbl* Produced Water Storage Tanks FUG-1 FL1 FL2 TRK-LOAD Fugitive emissions from component leaks Aereon Air Assist Flare Serial No. FS00001510 Installed: August 11, 2017 Aereon Air Assist 60' Flare, Produced Gas Flare Serial No. FS000001534 Installed: August 11, 2017 Truck loading for condensate/oil and produced water (backup for pipeline) Control Equipment FL2 Inspection Comments Added Noted 24 tanks on s/w corner of the pad directly across from compressors attached to tall flare, no emissions with IR from tanks or flare. Additional 4 tanks on n/w corner of pad with air assisted flare. No emissions from those 4 tanks, but emissions from the air assisted flare holding together, video taken (MOV_2726). None (IEU*) None (IEU) None None None None (IEU) No emissions from separator with IR. Noted 6 tanks attached to air assisted flare on eastern edge of pad, no tank emissions detected with IR. Saw no emissions from tops of any storage tanks. Not sure which flare is which, flare attached to 4 tanks on the n/w corner of the pad (closest to Targa facility) had emissions holding together. No unloading observed. Section II. NSPS JJJJ The permit lists applicability for ENG 2 and ENG 3 from Table 2 (Section II.A), however we are receiving NSPS JJJJ results for a third engine (serial JFE01145) not listed in this permit, see performance tests received by EPA below. 6 Unit ID Serial # Date Test Notice Rcvd 806866 (Unit 1) AG1006 (Unit 2) AG1017 (Unit 3) 806866 (Unit 1) AG1006 (Unit 2) AG1017 (Unit 3) JFE00926 JFE01058 JFE01145 JFE00926 JFE01058 JFE01145 10/5/2020 10/5/2020 10/5/2020 8/5/2019 8/5/2019 8/5/2019 Date Test Report Rcvd Test Date 11/2/2020 11/2/2020 11/2/2020 10/30/2019 10/30/2019 10/30/2019 10/27/2020 10/27/2020 10/27/2020 10/25/2019 10/24/2019 10/24/2019 Rule Applicability NSPS JJJJ NSPS JJJJ NSPS JJJJ NSPS JJJJ NSPS JJJJ NSPS JJJJ Test Results Passed Passed Passed Passed Passed Passed NSPS JJJJ required notice of testing, appropriate test methods and 3- one hour test runs all compliant for the listed tests. Section III. NSPS OOOOa Title V permit lists NSPS OOOOa applicability to reciprocating compressors Ariel JGD4 attached to engines ENG 2 and ENG 3. The NSPS OOOOa annual report dated 10/30/2018 lists two Ariel JGD4 reciprocating compressors attached to ENG 002 and ENG 003 but no source is listed, assuming it should be Clarks Creek CTB. Report just lists "1 month" for each, not sure what that means, 1 month from the last rod packing change out? Annual Title V certification submitted on 3/24/21 lists the following rod packing timelines. The rod packing must be changed once every 36 months per 60.5385a(a)(2). Title V permit also lists applicability of Clarks Creek's fugitive emissions components requiring development of a fugitive emissions monitoring plan (per 60.5397a(b)-(c)) and semi annual survey of equipment (per 60.5397a(g)(1)) according to the fugitive emissions monitoring plan. Any repairs must be made within 30 days (per 60.5397a(h)(1)-(2)). Per EOG's Annual Compliance Certification, leak surveys were conducted on 5/28/2020 and 12/2/2020. Two (2) leaks were discovered during the 12/2/2020 survey and both were repaired and rechecked within 30 days. Section IV. MACT HH Title V applicability section for MACT HH lists the 20 MMscfd TEG dehy controlled by "FL-1". Permit Table 2 lists FL-1 as an Aereon Air Assist flare. Onsite, EPA observed the only dehy controlled by a Cimarron flare (with emissions observed via FLIR). Based on the Title V permit at Section IV.A Applicability requiring compliance with major source HAP provisions in 63.765 and the annual 7 compliance certification, it's clear EOG complies with MACT HH by controlling the process vent to reduce Benzene emissions below .9 megagrams per year 63.765((b)(2). Using the IR camera, the closed vent system showed no detectable emissions, thus in compliance with 63.771(c). EOG reported Benzene emissions at 0.2258 tons per year in their 2020 Annual Title V Compliance Certification received 3/24/2021. The Cimarron model CEI-160 enclosed combustor is listed on the "Performance Testing for Combustion Control Devices Manufacturer' Performance Test NSPS OOOO/OOOOa and MACT HH/HHH" list of approved control devices (link) and thus does not require testing. However, EPA observed slight emissions from device while onsite. Because the actual average emissions of benzene from the dehy unit are less than 0.90 megagram per year, this unit is exempt from monitoring and reporting per MACT HH, 63.764(e)(1)(ii). However, EOG noted this unit is part of the IR inspections performed in compliance with NSPS OOOOa. Section V. MACT ZZZZ Title V indicates compliance with MACT ZZZZ if through compliance with NSPS JJJJ per Section V.C. No further evaluation required. Section VII. General Provisions EOG paid their 2020 fees in 2021 on time. Not going to pick on 2019 fees in 2020 due to COVID since their 2020 fees made it on time in 2021. Title V Annual Emissions & Fees per Air Program Tracking Year Rec'd NOx VOC Formaldehyde 2020 3/30/2021 75 91.4 5.4 2019 4/27/2020 39.2 190.2 4.4 2018 (initial app) 7/30/2018 40.3 129.1 2.2 Fees Paid $10,014.67 $12,821.45 $11,083.70 8 Appendix A: IR MOVIE LOG Date 8/19/2021 8/19/2021 File MOV_ MOV_ 8/19/2021 8/19/2021 8/19/2021 MOV_ MOV_ MOV_ Name 2726 2727 2728 2729 2730 Comment EOG Clark's Creek site vid and inefficient air assist flare EOG Clark's Creek emissions out of dehy ECD EOG Clark's Creek inlet piping dehy ECD & emissions from ECD EOG Clark's Creek intermittent pilot flame from dehy ECD EOG Clark's Creek reboiler still vent valve open Files MOV_2726 and MOV_2727 were sent to EOG, upon request during September 2, 2021 phone call, via GoAnywhere file sharing service on September 7, 2021. 9 APPENDIX B: Email exchange between EPA and EOP post inspection 10 11 12 7. Production Summary June 2021.xlsx 13 8. Production Summary_CY2020.xlsx 14 Cimmaron Model CEI-1-30.jpg 15 9. Well List with API, NDIC, Status.xlsx 16