AIR Texas Commission on Environmental Quality Investigation Report Marathon Oil EF LLC CN603988692 YOSKO 1 PRODUCTION FACILITY RN106204217 Investigation 987182 Incident 16 3 Investigator: CAROL MCGRATH Site Classification AIREI APPLICABLE Conducted: 02/03/2012 -- 03/30/2012 NAIC Code: 211111 SIC Code: 1311 Program(s): AIR EMISSIONS INVENTORY Location FROM INTX KARNES CITY GO WEST ON FM 99 3.4 MI TURN ON UNNAMED LEASE RD G0 0.3 MI TO SITE Investigation Type Compliance Investigation Additional 97998 Address: Activity Type REGION 13 - SAN ANTONIO GFIR - AIR GFIR - GAS FIND INFARED CAMERA AIRCOMPL -- AIR CMPL -- AIR COMPLAINT INV FIAIRODOR -- AIR FIAIRODOR - FOC INV ODOR SURVEY Principaltsi Role Name RESPONDENT MARATHON OIL EF LLC Contacttsi Role Titie Name Phone Regulated Entity Contact HES SUPERVISOR MS KATIE RICKLE (713) 499-3363 EAGLE FORD ASSET Cell (713) 858-6029 TEAM Work (210) 561-4207 Regulated Entity Mail Contact MR VIJAY KURKI (7133 499-6746 Work (210)561-4209 Cell (713) 408-6775 Other Staff Member(s) Role Name Investigator ROBERT REED Supervisor GEORGE ORTIZ Investigator FELISCHA CULLINS QA Reviewer JEANETTE SALAZAR Associated Check List Checklist Name |_J_nm1r_n_<2 AIR COMPLAINT INVESTIGATION 937132 AIR FOCUSED INVESTIGATON - ODOR SURVEY 937132 YOSKO 1 PRODUCTION FACILITY -- KARNES CITY 21312012 to 3/3012012 lnv. - 987182 Page 2 of 6 EQUIPMENT MONITORING AND SAMPLING 987132 Investigation Comments INTRODUCTION On January 30, 2012, a complaint notification of odors and mist from an unknown source was registered with the Texas Commission on Environmental Quality (TCEQ) Office in San Antonio via The Complainant alleged of being impacted by a terrible odor accompanied by a that burned the eyes and nasal areas, and caused tightening in the chest. This has happened four times in the past month at around two o'clock in the morning. The Complainant .- . also experiences the following when driving on west Farm to Market (FM) Road 99 -exitin,g.Karnes City, usually in the time frame of 1915 to 1925 hrs: watery eyes, runny nose, burniffg throat and hoarseness of the voice. In addition to these the Complainant also notices that a fine mist of a greasy, yellow substance collects on the windshield. The Complainant further described the odor as a "rotten egg" smell. Daily Narrative The investigation was assigned to Ms. Carol McGrath, Environmental Investigator (El) for the TCEQ Air Section of the San Antonio Office on January 31, 2012. On February 2, 2012, the El contacted the complainant to obtain additional information and to schedule the investigation for February 3, 2012. The El arrived in Karnes City, Texas at approximately 1100 hours (hrs). The weather conditions were as follows: the ambient air temperature was 68 degrees Fahrenheit, winds were out of the south southeast at 13 to 26 miles per hour, the sky had high scattered clouds. The El traveled west on FM Road 99 out of Karnes City, Texas. Located approximately one mile out of Karnes City on the northwest side of FM Road 99, was the Marathon Oil Facility - Carter Unit. The TCEQ Regulated Entity Number (RN) is RN106247950 and the Air Registration Number is 98993. Equipment at this facility included a flare, six large storage tanks, one small tank, two vertical separators, a heater, one column unit, and one compressor. The flare at this site was observed to be emanating black smoke. No odors were detected emanating from this facility at that time. All of the facilities observed in this investigation were within six miles from Karnes City on West FM Road 99. The second Facility observed was located on the southeast side of FM Road 99 diagonally across the road and south of the Carter Unit. This facility was signed as the Marathon Oi|--Egbert Miller Unit. This facility was equipped with seven brown storage tanks and one larger black tank. No information was found in the TCEQ database regarding this facility. No odors were detected emanating from this facility at that time. Further west on FM Road 99, at approximately two miles out from Karnes City, there was a third Marathon Oil Facility - the East Longhorn Central Facility. The TCEQ RN is RN106278328 and the Air Registration Number is 99759. This facility was equipped with a flare, ten large storage tanks, two compressors, a heater, and a separator as observed from the road. No odors were detected emanating from this facility at that time. The next facility observed on the northwest side of FM Road 99 was a Marathon Oil Facility - Zaeske-Echols 1H, which appeared to be a well site. No information was found in the TCEQ database regarding this facility. No odors were detected emanating from this facility at that time. The next facility observed on the northwest side of FM Road 99 was Marathon OiI--Yosko Unit and next to this site was Marathon Oil - Yosko Kinkler Unit. Both of these appeared to be well sites. No information was found in the TCEQ database regarding these facilities. No odors were detected emanating from these facilities at that time. The final facility observed was located approximately six miles west on FM Road 99 on the northwest side of the road. This facility was the Marathon Oil--Sugarhorn Central Facility. The TCEQ RN is RN106278377 and the Air Registration Number is 99763. This facility was equipped with a flare (which was emitting black smoke for more than a 15 minute observation time period), YOSKO 1 PRODUCTION FACILITY - KARNES CITY 2l3l20'i2 to 3/1 /2012 inv. - 987182 Page 3 of 6 ten large, black storage tanks, and three green smaller storage tanks, as observed from the road. No odors were detected emanating from this facility at that time. The flare at this site continued to emanate black smoke throughout the observation time period. The El then interviewed the Complainant. The Complainant stated that odors had not been detected on the day ofthe investigation, however, on February 1, 2012, odors were detected and the Complainant also noticed that there were moisture droplets on the vehicle windshield. When the moisture was rubbed between the fingers, the substance felt sticker than plain water. There had been no rain observed on that day. The El asked the Complainant to keep an odor log of dates. times. and duration that odors were experienced. The fit informed the Complainant that during the investigation no nuisance odors had been detected. There are numerous oil and gas operations up and down FM 99 Road and several are located nearthe complainant's property. On February 8, 2012, the El contacted Mr. Vjay Kurki, Environmental Manager for Marathon Oil. The odor complaint issue was explained to Mr. Kurki. Mr. Kurki stated that all of the referenced facilities had recently been purchased by Marathon Oil from Hilcorp Energy Company. He further stated that since the purchase, the Marathon Oil Staff have been making upgrades and repairs to all of the facilities. When inquiries of the smoking flares were presented to Mr. Kurki, he stated that Marathon Oil was aware of the smoking flares and biowers were being added to the flares and other adjustments were being attempted in order to repair the flares and make them operate properly. Mr. Kurki also informed the El that Marathon Oil had submitted a letterto the TCEQ indicating that after purchasing the facilities from Hilcorp Engery Company, Marathon Oil planned to use the provisions under the Texas Environmental, Health, and Safety Audit Privilege Act, (Audit Act) to perform an internal audit of all the properties. Mr. Kurki also provided contact information for a Marathon Oil Representative On~Site. This contact information was provided to the Complainant. On March 1, 2012, a TCEQ Reconnaissance Team, (Recon Team) made up of Ms. Felischa Cuilins, and Mr. Robert Reed and Ms. McGrath met with Marathon Oil Representatives at several Marathon Oil sites in the Complainant's area. A Toxic Vapor Analyzer (TVA), MiniRae, and QRae were used to monitor for volatile organic compounds (VOCs) and hydrogen sulfide (H23) emissions. In addition, the Region's FLIR Systems Infrared (IR) Camera (which is capable of detecting emissions and/or leaks of VOCs) was obtained to use during the investigation. The weather conditions during this investigation were as follows: ambient air temperature was 77 degrees Fahrenheit, skies were partly cloudy and winds were eight to sixteen miles per hour. The El Team stopped near the intersection of Highway 123 and Highway 80 to conduct instrument verification and calibration at approximately 1000 hrs. The TVA was verified. The MiniRae, and QRae were calibrated per standard procedures. The Recon Team proceeded to the Marathon Sugarhorn Central Facility arriving at 1040 hrs. The TCEQ RN is RN106278377 and the Air Registration Number is 99763. The equipment at this site is listed above in the first description ofthis facility. On the north fence line nearest FM Road 99, the TVA detected 3.0 ppm, at that time there was a tanker truck unloading on site and there was also vehicular traffic transiting on the road. North of the water tanks at this site the TVA detected a maximum of 24 ppm. The readings were thought to have been affected by the truck loading and the nearby road traffic. The MiniRae was exhibiting high readings and it was determined that the instrument required a new filter. The MiniRae was turned off and not used during the remainder of the investigation. The next site surveyed was the East Longhorn Facility north off FM Road 99, RMO6278328 and Air Registration Number 99759. Equipment at this site is described above in the first visit to the facility. During this survey no odor were detected and the monitoring instruments were non-detect as well. The third site surveyed was the Marathon Oil -- Yosko Number 1 Production Facility, RN106204217, and Registration 97988. This site is located about a mile west of the East Longhorn Facility north off i-"M Road 99 and was not surveyed during the investigation of February 3, 2012. Equipment at this site included the foilowing: one compressor, one heater treater, one glycol dehydrator, flare and five condensate tanks. The TVA detected 1,100 near the site gauge on the separator. The leak was also visible with the IR Camera. The Recon Team YOSKO 1 PRODUCTION FACILITY - KARNES CITY 2/3/2012 to 3l1l2012 lnv. -- 987182 Page 4 of 6 evacuated the area quickly to prevent exposure. The Els informed the Marathon Oil Representatives of the leak and indicated that the leak shall be repaired as soon as possible. Mr. Vijay stated that this site is to be converted to a test well facility and will be piped to a central tank battery facility and the equipment at the facility will not be used and will be removed. This facility is located less than a mile from the Complainant's residence. The fourth and final site surveyed was the Jonas~1 Unit, an oil and gas well drilling site. No odors were detected upon approaching the site. Moderate diesel fumes were detected on site emanating from the engine being used for drilling. The Operator stated that the drilling phase of the well had taken much longer than expected. On March 2, 2012 an electronic mail was transmitted to the Marathon Oil Representatives as follows: Please provide GPS coordinates, TCEQ Reg_istration, Permit, and or identification numbers for the Jonas-Unit that_ was detected to be leaking by the TCEQ Recon Team on March 2012.. Repair, replacement. or shut down of this unit should occur as soon as possible, as the alternative shall be recommendation of a nuisance violation. An electronic mail was received from the Marathon Oil Representative on March 5, 2012 stating that the leak was around the valve near the pneumatic controller and had been repaired on March 1, 2012. On March 30, 2012, the El was in the area and retrieved evidential documentation from the Complainant. The El was unable to use the Complainants evidential documentation in the investigation and the evidential documentation was returned to the Complainant. The Complainant was informed that the Complaint investigation would be closed with an additional issue. Furthermore, if nuisance odors or other environmental issues arise the Complainant should again contact the TCEQ. Several unanswered voice mails were left with the Complainant to inquire if the air quality issues of the registered complaint had improved or not. Exit interview An exit interview was not conducted at the end of this investigation. On March 2, 2012 an electronic mail was transmitted to the Marathon Oil Representatives -as follows: Please-provide GPS coordinates, TCEQ Registration. Permit, and or identification numbers forthe Jonas Unit that was detected to be leaking by the TCEQ Recon Team on March 1, 2012. Repair, replacement, or shut down of this unit should occur as soon as possible, as the alternative shall be recommendation of a nuisance violation. This will be noted as an additional issue in the investigation report. Note: The EIP is-activated by any type of enforcement action and serves to inform the regulated entity of any alleged pending or outstanding non--compliance issues. GENERAL FACILITY AND PROCESS Process Description This investigation was conducted over a general area of FM Road 99 west of Karnes City, Texas to determine from where odors and a greasy mist could possibly be emanating. Several Marathon Oil Facilities were surveyed, including the Marathon Sugarhorn Central Facility, the East Longhorn Facility, Marathon Oil Yosko Number 1 Production Facility, and the Marathon Oil Jonas Unit, a drilling site. BACKGROUND Current Enforcement Actions There was no current enforcement action resulting from this investigation, as there was no issue of non--compliance noted during the investigation. There is an additional issue which is discussed Additional issue Section below. Agreed Orders, Court Orders, and Other Compliance Agreements Not Applicable Complaints Not Applicable YOSKO 1 FACILITY -- KARNES CITY 2/3/2012 to 3/1/2012 Inv. - 987182 Page 5 of 6 Prior Enforcement Issues Not Applicable ADDITIONAL INFORMATEON Conclusions and Recommendations On February 3 and March 1, 2012, a complaint investigation for odors and mist from an unknown source was conducted. No nuisance was verified by the investigator during this investigation at this time. An Additional issue is noted as referenced below. Adciitionai Issue Although no nuisance violation was verified, it is possibie that the leak around the valve near the pneumatic controller at the Yosko Number 'i Production Facility, and Registration 97988, may have created a nuisance odor situation. The leak was repaired the day of discovery and since then the site has been converted to a test well facility and is now piped to a central tank battery and the equipment at the facility be removed. A test separator will operate on site. Description item 1 Additional Comments Although no nuisance violation was verified, it is possible that the leak around the valve near the pneumatic controiler at the Yosko Number 1 Production Facility, RMO6204217, and Registration 97988. may have created a nuisance condition. The teak was repaired the day of discovery and since then the site has been converted to a test well and is now piped to a central tank battery facility and the equipment at the facility will not be used and will be removed other than a test separator. Signed Date - Environmental Investigator Signed {Al Dategil/I 3,41/r Sjupen/isor YOSKO 1 PRODUCTION FACILITY - KARNES cm' 21312012 to 3m2o12 Inv. -987182 P399 3 0f 5 - Attachments: (in order of final report submittal) Action Request (EAR) W805. Skemhes ,4Letter to Facility (specify type) investigation Report from the facility _Sample Anaiysis Results (Specify) 3 NOR Marathon Oil Company RN106204217 Yosko 1 Production Facility, Karnes City, Karnes County, Texas Air Complaint -- February 3, and -March 1, _2_0l_2_ ATTACHMENT 1 Documentation for Air Complaint Investigation 987182 of Marathon Oil Company Yosko 1 Production Facility Karnes City, Karnes County, Texas Kames City, TX on Yahoo! Maps, Driving Directions, and Traffic Page 1 of 1 ,fi? Htcanfi &gn0ul' Man; Yanm>> .Prm.t.} . .- 5.9.0 Terms of Use Privacy Feedback @2012 Yahoo! 103195 25 2/14/2012 W1 Search Results Page 1 of] Log In Search for W-1s Search W1 RESI-M5 Searched for: 1 - 2 of 2 results API No. 255-32260 Click on [ease name for detailed permit information Well . Wellbore .Ei__i_i_ng. Profile gmfiflg' Submitted MARATHON OIL 12 20 2011 255- -- . Apgrofled 730430 32260 1H 02 KARNES Horlzontai - 15000 Approved 12/23/20 1 1 'tt 255_ MARATHON OIL New 730430 EF LLC 1H 02 KARNES Horizontal . Yes 15000 Approved Approved 32260 (525398) UNITE Dull 01/11/2012 I 1 ..C_o.r1t.a.c.t. mg 25" ://webapps.r1fc. ?o0u.11tyCodo:25 5&api Sc-3qN . .. 5/ 8/20 1 2 3. 1 a Bryan W. Shaw, P11.D., Chairman Carlos Itubinstein, Comnn'ssioner Toby Baker, Commissioner Zak Covar, 1i'xecutive Director TEXAS COMMISSION ON ENVIRONMENTAL QUALITY Protecting Texas by Reducing and Preventing Pollution May 18,2012 Re: Investigation Request at Oil and Gas Exploration Sites and Facilities off Farm to Market Road 99, Karnes City, Karnes County, Texas Incident 164263, Investigation 987182 The Texas Commission on Environmental Quality (TCEQ) San Antonio Region Office has completed a final investigation in response to your concern regarding the dust complaint at the aboVe~refere11ced site. Enclosed is a copy of the final report indicating the results of the investigation. - Thank you for contacting the TCEQ with your concerns. If you have questions feel free to contact Ms. Carol McGrath of my staff at (210)403-4063. Sincerely, George Ortiz Air Section Manager San Antonio Region GO/cm TCEQ Region 13 - 14250 Judson Rd. - SanAntoni0,Texas78233~4480 - 21o--49o~3o96 Fax 21o--545~4329 Austin Headquarters: 512-239-1000 - tceq.texas.gov - How is our customer service? teeq.texas.gov/clistomersurvey rm rec_vrle:l pap:-1' stay-litiscll ink Bryan W. Shaw, l'l1.D., Chairman Carlos Rubinstein, COmn'IissiOner Toby Baker, Cornmissirmer Zak Covar, DI'rectOr TEXAS COMMISSION ON ENVIRONMENTAL QUALITY Protecting Texas by Reducing and Preventing Pollution May 18, 2012 Mr. Vijay K. Kurki, P.E., Senior HES Professional Marathon Oil 5253 Prue Road San Antonio, Texas 78249 Re: Additional Issue for Compliance Evaluation Investigation at: Marathon Oil Yosko 1 Production Facility 3.4 Miles West of Karnes City, Karnes County, Texas on State Highway 99 On North Side On Unnamed Lease Road 0.3 Miles RN106204217, TCEQ Registration 97998, Investigation 987182 Dear Mr. Kurki: On Februaiy 2 and March 1, 2012, Ms. Carol McGrath of the Texas Commission on Environmental Quality (TCEQ) San Antonio Region Office conducted an investigation of the above--referenced regulated entity to evaluate compliance with applicable requirements for air quality. Enclosed is a summary which lists the investigation findings. As a result of the investigation, no violations are alleged; however, please see the attached Additional Issue as a summary of investigation findings. Based on the information you have provided, the TCEQ has determined no further action is required. If you or members of your staff have any questions, please feel free to contact Ms. McGrath in the San Antonio Region Office at (210) 4o3~4o63. Sincerely, /lb George Ortiz Air Section Manager San Antonio Region GO/cm Enclosure: Summary of Investigation Findings TCEQ Region 13 - 14250 Judson Rd. - San Antonio, Texas 782334480 - 210-490-3096 - Fax 210-545-4329 Austin I-Ieadquarters: - tceq.texas.gov - How is our customer service? printed on in}: jib TECHNICAL REVIEW: AIR PERMIT BY RULE I Energy Company Mr. Jeffrey Voorhis, in I 106.352 2000-3131'-04 TO 202 106.492, 106.512 168693 Yosko 1 Production Facility Regulated Entity No.: Customer Reference No.: Account No.: Cityt'County: Permit by Rule Application August 5, 2011 CN600 125991 Project Type: Date Received by TCEQ: Date Received by Reviewer: from intx karnes city go west on fin 99 3.4 mi turn it on unnamed lease rd go 0.3 mi to site Karnes City, Karnes County Physicat Location: Responsible Official! Primary Jeanine Saiinas (713) 289-2912 Contact Name and Title: Environmental Coordinator Fax No (713) 289-2750 Technical Contacts' Consultant Phone No Email' Name and Title: Fax No.: ls confidential information included in the application? Are there affected NSR or Title permits for the project? This is a new site with no previously issued NSR or Title permits. Is each PBR 253250 tpy? Are PBR sitewide emissions 25t250 tpy'? Are there permit limits on using PBRS at the site? is PSD or Nonattainment netting required? This site is not one of the 28 named sources and emissions are below the federal significance as major source levels, therefore, PSD and NA review and netting are not required. Do NSPS, NESHAP, or MACT standards apply to this registration? MACT Subpart NSPS Subpart .l.lJ.l Does N02: Cap and Trade apply to this registration? This site is not located in the area. is the facility in compliance with all other applicable rules and The applicant represents they are in compliance with all applicable rules regulations? and regutations. I--lilcorp Energy Company has submitted a and supporting documentation to register the facility. The site consists of the following facilities: The facility is an oil and gas production facility consisting of gas separation and compression equipment and condensate and water storage tanks. Natural gas at the site contains up to 85 I-I28. Production from the Yosko I well enters a high pressure separator. Gas from the HP separator is sent to a glycol dehydrator then to sales; liquids are routed to a low pressure separator. From the LP separator, liquids are sent to a heater treater, gas is sent to a compressor and then to sales. From the heater treater, liquids are sent to the condensate and water storage tanks; gas is sent to the compressor. Condensate and water from the storage tanks and are loaded into tank trucks and transported off site. {Emissions from the condensate and water storage tanks are sent to the flare. Fiash gas from the tanks contains <0.001 tnoi% H23 (laboratory analysis, stain tube method) (1) Cat G3306TA compressor engine Giycol dehydrator Heater treater (5) 400>>bbl condensate tanks (1) 400-hhi water tank Condensate loading Water loading Fugitives (1) flare 1 TECHNICAL REVIEW: AIR BY RULE 97998 Hilcorp Einergy Cornpany -in Mr. Jetfrey Voorhis, PE. 168693 I Yosko i Production Facility 106.512 . 106.3 52 2000-Sill'-04 TO 106.492, ti 0 Fugitives: calculated using AP-42 factors. Gas analysis dated 'H28i'10. VOC 20.76wt% 50.5 Heater treater: AP-42 emission factors. 0.5 MMi3tui'hr, 8760 hrs//year, 124'? btursef, emission factor of ?00 Natural gas throughput: 0.9 8106.352 for Oil and Gas Production Facilities (1) There compressor engines and flare wiit meet the requirements of 1065 i2 and 106.492. (3) The site handles sweet gas and is iocated more than 750 Itfrotn the nearest oil"-site receptor. (4) Totai emissions of sulfur compounds are iess that . (5) Form CERT has been submitted. ?106.492 Flares greater than 1,000 Bttiltt'. Actual: 2056 Btui'fl"- 26.13 ftfsec tip velocity (C) The flare is located ?50i't from the nearest off-site receptor. (D) The flare does not emit hydrogen chloride. The flare"-emits-S02 and will exceed 0.53xl0E5xS02 emission rate. (B) A Form Pl-7 CERT was submitted. (C) Under no circumstances will liquids be burned in the flare. ?106.5l2 for Stationary Internal Combustion Engines and Turbines (1) Form PI-7 CERT and 'I'ablc.29 have been submitted. (2) The Cat is rated 203-hp and must oniy comply with subsections (5) and (6) (3) NA, there is no turbines. (4) NA, the engine will not be used for temporary replacements. (5) l'~'uei used by the engine will be field gas Condensate tanks: Tanits 4.0 and GORmetl1od. GOR flash liberation of separation water analysis dated 1028/10. Production rate 2'35 bbifday. API gravity 56.51, Water tanks: Tanks 4.0 and GOR method. GOR flash liberation of separation water analysis dated 7l28i'i0. Production rate 50 gravity 5655 I, Condensate Truckloading: AP-42, Chapter 5, section 5.2-4 equation. Saturation factor 0.6, 6.63 psia, 50 200 1003 7'5 Water Trucltloading: AP-42, Chapter 5, section 5.2-4 equation. Saturation factor 0.6, 6.63 psia, 50 200 18250 bbiiyear. Compressor engine: emission factors and manufacturer's data. Caterpillar manufacture date 06f2a'08, NSCR control. Fiare: Condensate and water tanks are routed to flare. Condensate tanks: i388?scfiday. Water tanks: 25.25 Flare tip diameter 0.1670, flare tip area 0022 ft. (2) Emissions will be less than 250 tpy each of CO and and iess than 25 tpy each of VOC and S02. (See estimated emissions table below). The flare is equipped with a tip designed to provide good mixing with air, flame stability, and with a tip velocity less than 400 flfsec for gases with a_ LHV (B) The Rate is equipped a continuousiy burning pilot and auto ignition system that assures gas ignition whenever vents are directed to the flare. The flare burn only combustible mixtures of gases containing only carbon, hydrogen, nitrogen, oxygen, sulfur, chlorine, or compounds derived from these elements. The gas mixture will always have a net or lower heating vaiue of at least 200 Btuffi-' prior to the addition of air. Ambient sampling or dispersion modeling, accomplished pursuant to guidance obtained front the executive director, was used to demonstrate NAAQS: is totai below NAAQS annual limit for ofltiti pg/mi (yesr'r10}? (7) NA, the compressor engines wit! not be used to generate etectricity. Engine Identifier I IEPN Max. I-iourly Concentration Max. Annual Concentration Ratio Annual Concentration Of NOJNOX (from table (Max. Annual Conc. NOJNOX (from Screcn3 modeling) (Max. Hourly Cone. heiovv) Ratio) 0033 (tie/In') we/m") ENG-1 53.90 4.31 - 4.31 Background Concentration fiir County 20 Hourly 70 Annually 23 .67 Hourly 115.82 Annuaiiy Is total below NAAQS hourly limit for of 100 ug/mi (yesmo)? Yes Yes -J/wu. 937132 Pa 2-5 TECHNICAL REVIEW: AIR PERMIT BY RULE 92998 Hiieorp Energy Company Mt Jeffrey P-13- ProjecrNo.: 168693 'tJ}:}ij HYoskol1'roduetionFaci1ity .. 106.352 TO 201 106.512 1-FEB.-27, 106.492, Yes and ll Meter .250 II 44 ijtlni 130 "How are clai How are men. and What control efficieney is ciaimedf? ENG--1 CAT I-1T--11-Ieatertreatcr <0.01 0.01 0.05 0.22 0.04 0.18 <0.0l 0.02 <0.01 0.02 <0.01 <0.0l Glycol Dehydrator-Reboilcr 0.001 0.005 0.020 0.086 0.016 0.0?2 NA NA NA NA 0.033 0.146 Giyeoi 1.183 5.182 Column Glyeoibehydrator-S1111 GoestoF1are 0.033 0.146 0.016 0.069 0.031 0.138 NA NA NA NA 0.008 0.03? Column FL--1F1areen1issionsfrom 0.233 1.014 0.042 0.186 0.06 0.27 <00} <0.0l <0.0l <0.0l <0.0l <0.01 Condensate Tank 1 FL<<1Flareclnissionsfrom 0.233 1.014 0.042 0.186 0.085 0.371 <0.01 <0.01 <0.0l <0.0i_ <0.01 <0.0l Condensate Tank 2 0.233 1.014 0.042 0.186 0.085 0.371 <0.01 <0.01 <0.01 <0.0l <0.01 <0.01 Condensate Tank 3 FL-1Flarccmissionsfrom 0.233 1.014 0.042 0.186 0.085 0.321 <0.01 <00} <00! <00] <00] <0.01 Condensate Tank 4 F1,-1Flarecmissionsfrom 0.233 1.014 0.042 0.186 0.085 0.371 <0.0l <0.0l <00} <00} <0.0l Condensate Tank 5 3 'gm. '5'8'?132- 1 TECHNICAL REVIEW: PERMIT BY RULE Mr. Jeffrey Voorhis, P13. . -. 106.352 2000-3131204 TO - 1013.492, -. .. :3 -. 105-513 -: (LO . C) 0.002 0.025 <0.01 0.0: 0.01 0.02 <0.01 <0.01 <00: <0.01 <00: <0.01 Hiicorp Energy Company :5 Yosko 1 Production Facility Fiare emissions from Water Tank I CLD-1 Condensate ioading 34.631 7.109 WLD-I 'Water loading 0.346 0.013 FUG Fugitives 0.667 2.922 311.199 21.190 1.192 5.221 230410.090 0.021 0.091 0.021 0.091 0.011 0.047 Site Review Required? Site review not required. August 29, 201 1 Mr. Jeffrey Voorhis, PBR Distance Limits Met? Applicant represents they are more than 75011 from the nearest property line and off-site receptor. August 29, 201 1 Mr. Jeffrey Voorhis, P13. A 4- . -1 arr; See Hard Copy. PRINTED NAME: Mr. Jeffrey Voorhis, RE. Mr. Monico Banda DATE: August 29, 2011 August 30, 2011 Base P011113Project Coirqflexffy Description and Technieai Reviewer Project Points Assessment: Final Reviewer Project Points Confirmatiori: P3. 4, oz 2.5 Central Registry Internal Reporting Query Page 1 of 1 Res urces for'I'CEQEn1p}oyees was': /1 _M.aLn_Q_u_e_ry..E.ag1 I Program Area Search I IReguIated Entity Detaii Regulated I Entity Name: YOSKO 1 FACILITY RN. RN106204217 Status: Active Status Comment: Stand Alone: No physics! or street address on file. County: KARNES Physical FROM INTX OF US181 AND FM 99 IN KARNES G0 WEST ON FM 99 3.4 MI TURN ON UNNAMED LEASE RD Location: G0 0.3 T0 Nearest City:I KARNES zip Code=I|78118 fllfititudezl Longitude:II I IL 1-1 of 1 Records Affitiated Customers .4. Egg Begin Date End Date RE Comp Hist OWNER OPERATOR 11r1ar2o1s 1213113000 1-2 of 2 Records Program interests Program RE ID Type Addn Addn Alt RE Role Customer Begin Date -- Type ID ID Name Name End Date Status (CN) AIR NEW SOURCE I SITE REGISTRATION I ACTIVE I OWNER fl3!11f2IJ11-- I PERMITS FACILITY OPERATOR 1 11131201 1 AIR Nfiw SOURCE REGISTRATION 919% ACTIVE YOSKO1 PRODUCTION OWNER 11HBI2D11- PERMITS FACILITY OPERATOR Icentral Registry Giossary Centre! Registry Hetp I I Map of Regional Planning Areas I I Migrated Systems I For questions or comments regarding this T-Net page contact: This site was last modified: August 23, 2010 Pea. 7.4 .25 .. 3/2/2012 Cciitral Registry Internal Reporting Query Page I of 1 Resources fo IRegulated Entity Detail I Regulated Entity Name: I Status:I Active Status Comment: Sta None: Physical Address: FROM THE INTERSECTION OF INTERSTATE 81 AND FM 99 IN KARNES CITY TRAVEL TURN Location: ON RD AND TRAVEL 0.2 Mi TO SITE KARNES II s1a1e:I|Tx zip Code:II78118 I I Latitude: 23? 52 mm 29 sec 123374300} Longitude:II97? 55 min 32 sec (-97.925000; II CARTER NO 1 PRODUCTION FACILITY RN: RN1D62-47950 No physical or street address on file. County: KARNES 1-1 of 1 Records Affiliated Customers I an I 39.13 I Begin Date IEnd Date I RE Comp Hist I I owwen OPERATOR I 1111012011 I12r31z3c--Records Program interests Program RE ID Type Addn Adan Alt RE Role customer Begin Date -- Type ID ID Name Name End Date Status AIR new SOURCE SITE REGISTRATION e_0_ee_0 ACTIVE CARTER no 1 PRODUCTION ownen i1ii,coBpM_en_g3g,x_co11mur 10.r14r2011 - PERMITS FACILITY OPERATOR 1 1.1101201 1 AIR NEW SOURCE SITE REGISTRATION eggs; ACTNE CARTER no 1 PRODUCTION owuen 1111012011 - PERMITS FACILITY opemron 12r31r3000 [Central Registry Glossary I I Central Registry Help I I Map of Regional Planning Areas I I Migraied Systems I For questions or comments regarding this T-Net page contact: This site was last modified: August 23, 2010 P3 2/ 1 Central Registry Internal Reporting Query '12 Page 1 of 1 IReguIated Entity Detail I EAST LONGHORN CENTRAL FACILITY RN: RN106278328 Status: Active Status Comment: Stand Aione:II I No or street address on file. County: KARNES Physical FR KARNES CITY G0 ON CALVERT AVE TOWARD FM 99 MS PANNA MARIA AVE G0 0.6 MI TURN LEFT ONTO LocationTURN ONTO FM 99 8 LINE FACILITY I Nearest City:I KARNES CITY I Latitude:II28? 52 mwifl 12 sec (28.870100) II II State: TX ii Zip Code:II78118 Longitude: 97? 55 min 50 sec (-97.930520) 1-1 of 1 Records Affiliated Customers 4. I figig Begin Date I End Date RE Comp Hist I I owmzn OPERATOR 1112912011 I MA I 1-1 of 1 Records Program Interests Program RE ID Type Addn Addn Alt RE Rafe Customer Begin Date - Type ID Name Name End Date Status (CN) MR NEW SOURCE REGISTRATION PENDING ms? CENTRAL OWNER I 11.*2sr2o11 - PERMITS FACILYTY OPERATOR 1213113000 [Central Registry Giossary I I Centrai Registry Heip I I Map of Regional Planning Areas I I Migrated Systems] For questions or comments regarding this T--Net page contact: This site was last modified: August 23, 2010 25" . . 2/15/2012 Central Registry Internal Reporting Query Page 1 ofl I I?E?I}Iated Entity Detail I Regulated Entity Name: YOSKO 1 PRODUCTION FACILITY RN. RN106204217 I Status:I Active Status Comment: Stand I No physicai or street address on fife. County: KARNES Location: Go 0.3 MI TO SITE I Nearest City: IKARNES cm! State:I Tx II Zip Code:II78118 I Latitude: I Longitude:I I 1-1 of 1 Records Physical FROM INTX KARNES CITY GO WEST ON FM 99 3.4 MI TURN ON UNNAMED LEASE RD I Affiliated Customers 4. I Bgig Begin Date I End Date RE Comp Hist I OWNER OPERATOR 1msI2o11 I 1~2 of 2 Records I Program Interests Program RE ID Type Addn Addn Alt RE Role Customer Begin Date - Type ID ID Name Name End Date Status (ON) AIR NEW SOURCE SITE REGISTRATION ACTIVE YOSKO 1 PRODUCTION OWNER 0Bi11f201 1 PERMITS FACILITY OPERATOR 1m3I2o1 1 AIR NEW SOURCE SITE REGISTRATION 9129;} ACTIVE YDSKO 1 PRODUCTION OWNER I 11I1aI2o11 - PERMITS FACILITY OPERATOR I Central Registry Glossary I I Registry Help I I Map of Regional Planning Areas I I Migrated Systems I For questions or comments regarding this T-Net page contact: This site was last modified: August 23, 2010 I 7 0 187. P3. .25" .. 2/ 1 5/2012 Central Registry Internal Reporting Query Page 1 of 1 1{eso11i4cesfo1' . . Regulated Entity Detail SUGARHORN CENTRAL RN: RN106278377 I Status: Active Status Comment:II I Stand AlorIe:II No physical or street address on file. County: KARNE3 Physical FR KARNES CITY GO ON CALVERT AVE TOWARD FM 99 NS PANNA MARIA AVE G0 0.6 MI TURN LEFT ONTO US 181 8 G0 0.5 MI TURN ONTO FM 99 3 LINE ST CONTINUE ON FM 99 FOR 5.8 MI TURN RIGHT ONTO CR 209 omvs 235 FT TO on RIGHT Nearest City: KARNES CITY State: TX Zip Code:II78118 I Latitude: 28? 50 min 30 sec Longitude: 97? 59 min 24 sec (-97.989310) I 1-1 of 1 Records Affiliated Customers A R.9.ie. I Begin Date End Date RE Comp Hist I Ma_ImIfi9igmJ??_I?_c ownen OPERATOR I 1129:2011 1213113000 Jfi I 1-1 of 1 Records IProgram interests I Program RE ID Type Addn Addn Alt RE Role Customer Begin Date - Type ID ID Name Name End Date Status (ON) AIR NEW SOURCE I I REGISTRATION 99.3.5.3 I PENDING I SUGARHORN CENTRAL OWNER mm 11I2eI2o11- PERMITS FACILITY OPERATOR 12f31!3000 Icentrai Registry Glossary Centre! Registry Help I I Map of Regional Planning Areas I I Migrated Systems I For questions or comments regarding this T--Net page contact: This site was last modified: August 23, 2010 5 2/ 5/2012 Rebecco K. Skibo Senior Attorney a Marathon Oi! Company 5555 Son Felipe Street Houston, Texas 77056 Telephone 7i3~296-2584 Fox 7l3--5i3~4-125 November 1, 2011 WA CERTIFIED MAIL AND FACSIMILE TO 512--239-4390 Richard A. Hyde, P.E Deputy Director, MC 172 TCEQ Office of Compliance and Enforcement PO. Box 13087 Austin, TX 78711-3087 Re: Marathon Oi! EF LLC, Notice of Audit of Eagie Ford Assets Acquired November 1, 2011 Mr. Hyde, The purpose of this fetter is to notify the Texas Commission on Environmentai Quality that Marathon EF LLC (Marathon) intends to audit certain facilities as described herein in accordance with the Texas Environmental, Health, and Safety Audit Privilege Act, Tex. Rev. Civ. Stat. Ann. Art. 4447cc. On November 1, 2011, Marathon finalized a transaction in which it acquired the facilities described herein from Hiicorp Energy Company (Hllcorp). As the new operator of these facilities, Marathon intends to conduct an audit that evaiuates compliance with the health, environrnentai, and safety laws of the-St-ate of Texas. The facilities that will be covered by this audit are detailed in the attached table. This audit review will begin on November 1, -2011, -and will be completed wi-thin six months. Piease do not hesitate to cal! me at (713) 296-2584 if you have any questions. Best Raga rds, Rebecca K. Skiba Pea'! Via Eiectronic Copy CC: Kirk Asset Manager (Marathon) Mark Mick, Operations Manager (Mar_atho_n) Katie Rickle, HES Supervisor (Marathon) gash. 13% 2.5 Facility/Well Name Facility Type County West Excelsior Wells Central Atascosa Tet Skid Esse Smith A-1 Esse Smith Test -Skid Henke Test Skid Henke 8 -1H Test Skid Schroeder Chapman>> 1H Test Skid East Excelsior Central Facility Atascoa Wells . Carpenter-Thom p_son--1H Chapman Pfiel--1 Test Skid Chapman Rothe~1H Test Skid De-Atley May A-1H Test Skid DeAtley May B-1H Test Hierholzer Ret2:loff--1H Test Skid Hierholzer Seewald Test Skid Hollub Test Skid Kellner Jonas-1 Test Skid Kellner McMahon Test Skid Stewart Giese--1 Test Skid Griffen DeAtley Test Skid Griffen DeAtley A Test Skid DeAt?ey Hollub Test Skid DeAt|ey Griffin Test S-kid Stewart Finely--1H Test S-kid Central Excelsior wells Test "Skid Central Facility Atacsa Retzloff May Retzloff Torn~1H Test Skid Mauch Krueger Test Skid Mauch Tom -1H Test Skid 2.5" Sugarhorn Central Facility Karnes wens .- .- - -. Holland Opelia Test Skid Holland Brown Test Skid Scheele I-iuth A Test Skid Scheeie Huth 8 Test Skid Hedtke --1H Test Skid Smith Test Skid Vaidos FoggeIIe--1H Test Skid May Ryan Unit A Test Skid May Ryan Unit 3 Test Skid East Longhorn Wells Central Fa.c.i_litv Karnes Rippstein Chapman Rogers Test Skid Yosko Kinkler -- 1%-i Test Skid Egbert Miiler--1H Test Skid Salge kinkler-1H Test Skid Salge Busselman -1H Test Skid Rippstein Rafter Test Skid Rippstein Gothhardt--1H Test Sk-id Sperencel Peck --1H Test Skid North Longhorn Central Facility Karnes Wells .. -. . . . - Oxford --1H Test Skid Martinez Henke 1H Test Skid Forister 541 A Test Skid Forister 541 Test Skid Mohr Hons--1H- Test Skid Medina Jonas A Test Skid Medina Jonas 8 Test Skid 74 Ranch wells Middle Mccowen 1 Middle Mccow-en 2 Middle Mccowen -- 3 Middle Mccowen 4 Central Facilit. Atascosa Test Skid Test Skid Test Skid Test Skid pa. Union Central Facility Gonzales Cherry Turk Test Skid Cherry Bilksy Test Skid Bilsky Test Skid Iwells . . .. -. Mauch Stand -Alone Facility Atascosa Hierholzer Stand Alone Facility Atascosa McCoy Stand Alone Facility Live Oak Tom Stand Alone Facility Atascosa Barboza "St-a nd Alone Facility Ka mes Best Fenner "Stand Alone Facility Karnes Buehring 'Stand Alone Facility Kames Direct Asset Stand Alone Facility Karnes Dewbre Johnson Stand Alone Facility Karnes Easiey Stand Alone Facility Karnes Foster Sta rid Alone Facility Karnes Franke Stand Alone Facility Karnes Hollrnan Stand Alone Facility Karnes Jordan Stand Alone Facility Kames Kenedy Jones Stand Alone Facility Karnes Kenedy-1i-i Stand Alone Facility Kames Kenedy--2H Stand Alone Facility Karnes Kowalik Stand Alone Facility Karnes Luna Stand Alone Facility Karnes May Sta_nd Alone Facility Karnes Morgan Stand Alone Facility Kar-nes Patino Stand Alone Facility Karnes Pfiefer Stand Alone Facility Kames PMT Stand Alone Facility Karnes Rancho Grande Stand Alone Facility Karnes Sienkiewicz Stand Alone Facility Karnes Turnbull #1 Stand Alone Facility Karnes Turnbuli #2 Stand Alone Facility Kames Turnbuli #3 Stand Alone Facility Karnes Turnbull #4 Stand Alone Facility Karnes Turnbull #5 Stand Alone Facility Karnes Turnbull #6 Stand Alone Facility Kames Urrutia Stand Alone Facility Karnes Weston Stand Alone Facility Karnes Yosko Stand Alone Facility Karnes Jonas-1H Stand Alone Facility Karnes Carter Stand Alone Facility Karnes P3- He'? Cater-Salge Stand Alone Facility Karnes Yosko Borgfield Stand Alone Facility Karnes Best Huth St'-and-Alone Facility K-arnes Davenport Facility Karnes Giiley Stand_'Alon_e Facility Karnes Sheele -- 1H Stand Alone Facility Karnes Barnha rt #1 Sta nd Alone Facility Gonzales Barnhart #2 Stand Alone Facility Gonzales Barnhart #3 Stand Alone Facility Gonzales Bamhart #4 Stand Alone Facility Gonzales Barnhart #5 Stand Alone Facility Gonzales Barnhart #6 Stand Alone Facility Gonzales Dubose 1 Welilheafol only Gonzales- Dubose 2 Well head only Gonzales Dubose 3 Well need only Gonzales Duloose 4 Well head only Gonzales E. Troell Stand Alone Facility Gonzales Modern George #1 Stand Alone Facility Karnes Modern George #2 Stand Alone Facility Karnes Hagen #1 Stand Alone Facility Gonzales Hagen #2 Stand Alone Facility Gonzales i(ifer Test Skid Gonzales Leske-Lott Stand Alone Facility De Witt Robinson Troell Test S'ki'cl G_onz-ales Troell. 'Est. Test Skid Gonzales Barnha rt Sales P_oin_t- Stand Alone' Facility Gonzales Ann Friar Thomas St-and Alone Dewitt Beam 'Meyer Sk-id" Unk. Milckelson Witte Test Skid Unk. Giese Test--"Skid Unk. Jarvu 137- Pc? l'7ol Z5 Carol Mcgrath From: Kurki, Vijay K. (MRO) [vkkurki@marathonoii.com] Sent: Friday, May 04, 2012 31:47 AM To: Carol Mcgrath Cc: Rickie, Katie M. (MRO) Subject: RE: Odor Complaint Ms. McGrath, Yes. Yosko No 1 Production Facility was converted to test well eariy last month Ail production from this well is going to a central tank battery facility. lam not sure if ail the production equipment is been removed yet. But only a test separator is being used at this time. Let me know ifyou need any other information. Sincerely, Vijay Kurki, P.E. Senior HES Professionai Eagle Ford Asset 210--561~4209 713-408-6775 Marathon Qii Corperetion. From: Ca roll Sent: Friday, May 04, 2012 11:36 AM To: Kurki, Vijay K. (MRO) Subject: RE: Odor Complaint Greetings Kurki: Can you tell me if Yosko No 1 Production Facility has been converted to a test well facility? Has all production equipment with the exception of the separator been removed following the conversion? Yosko No 1 Production Facility Latitude 28.8588 N, Longitude 97.9532 4 7 3 to TCEQ Registration No: 97998 .3 353. 1 {it . Sincerely, Carol McGrath Air Section Senior Environmental Investigator Texas Commission on Environmentai Quality (TCEQ) Region 13 14250 Judson Drive San Antonio, Texas 78233 210~490>>3096 210--S45--4329 fax gyself (0 2/24 KO"*vaa /22 /91? 1/1742 ZENNE 'aw mosqmm Greg 77 92/3/OJ2 *?a?2~z37g /0 PM 9? M/e:stV A, <04 CZ/wf 2 502.2 Fm 1102, Ovouw 23. .. .. J. 4,30 /_/Lug (959 up oat /Site EBUWQNAM Jam. QM aowlaye Wd/ i