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Home My WebLink AboutDAQ-2024-0072541 DAQC-PBR100522001-23 Site ID 100522 (B1) MEMORANDUM TO: FILE – OVINTIV USA INC. – Karl UT 16-19 4-1 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Stephen Foulger, Environmental Scientist DATE: December 8, 2023 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: November 2, 2023 SOURCE LOCATION: Karl UT 16-19 4-1 Lat:40.11651 Long: -110.03083 Business Office: 370 17th Street, Suite 1700 Denver, CO 80202 SOURCE TYPE: Tank Battery Duchesne County API: 4301354064, 4301354068 SOURCE CONTACTS: Brandon Lithgoe, Local Contact Phone: 281-847-6093, Email: brandon.lithgoe@ovintiv.com Ryan Zillner, Local Contact Phone: 720-876-3144, Email: ryan.zillner@ovintiv.com 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, 40 CFR 60 Subpart OOOO. 2 SOURCE EVALUATION: Site Type: PBR- Controlled Controlled by flare Site powered by Engine The source registered: 547500 Estimated Oil BBL. DOGM current 12 month rolling production is: 14,4865. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Engine - Engine - Natural Gas 4-Stroke Rich Burn Make - Doosan Model - D14.6L Mfg Year - 2015 Horse Power - 402 Combustion - Natural gas, Pneumatic, Tank 3 General Provisions 4 VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] In Compliance. Good VOC emissions reduction observed at the time of inspection. 5 Air pollution control equipment is designed and installed appropriately, maintained and operated to control emissions. [R307-501-4(2)] In Compliance. Control equipment found properly designed, maintained, and operated at the time of inspection. 6 Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-2] In Compliance. Vessel vent lines were properly sloped away from the flare at the time of inspection. 7 Flare inlet lines are equipped with a fire arrestor, pressure gauge, inlet pressure regulating valve and other components according to the engineering design, the manufacturers specifications or good practices for safety and emissions control. [R307-501-2] In Compliance. Flare inlet lines found properly engineered and installed at the time of inspection. 8 10 Flares 11 Any flare has an operational auto-igniter. [R307-503-4] In Compliance. Flare was found with operational auto igniter properly installed at the time of inspection. 12 Tank Truck Loading 13 Truck loading is done by bottom filling or submerged fill pipe [R307-504(1)] In Compliance. Truck loading was set up properly for bottom or submerged filling at the time of inspection. 3 14 A vapor capture line is used during truck loading if subject to storage vessel emissions controls of R307-506-4(2). Effective 7/1/2019 for sources existing before 1/1/2018, and upon construction for new sources.[R307-504-4(2)] In Compliance. Vapor capture line available for use during truck loading. 15 Oil and Gas Industry Registration Requirement 16 The source is registered with the DAQ. [R307-505-3(3)] In Compliance. This source was found properly registered with the UDAQ at the time of inspection. 17 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)] Not Observed. 18 Storage Vessels 19 Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. Thief hatches were found closed and latched at the time of inspection. 20 VOCs from storage vessels are recycled, recovered or controlled by a device that is compliant with R307-508. Exempt if <8000 bbls crude oil per year, <2000 bbls condensate, or if uncontrolled emissions are <4 tons VOC per year. [R307-506-4(2)(a)] In Compliance. VOCs from storage vessel found properly routed and controlled at the time of inspection. 21 Emissions from emergency storage vessels are controlled according to R307-506-4(2), or are only used in emergencies, are emptied within 15 days of receiving fluids and are equipped with a liquid level gauge. [R307-506-4(4)] In Compliance. Emissions from all storage vessels found properly routed and controlled at the time of inspection. 23 Upon modification, the well site was re-evaluated against the thresholds of R307-506-4(2). [R307-506-4(6)] In Compliance. Well site was unmodified at the time of inspection. 25 VOC Control Devices 26 The VOC control device(s) required by R307-506 or R307-507 has a control efficiency of 95% or greater, operates with no visible emissions and has an operational auto-igniter according to R307-503. [R307-508-3(1)] In Compliance. VOC control device installed at the time of inspection is designed to operate at a destruction efficiency greater than 95 percent. No visible emissions were observed at the time of inspection. 4 27 Monthly AVO inspections are conducted on VOC control devices and associated equipment, and corrective actions are taken within 15 days. [R307-508-3(3)] In Compliance. These records were observed by DAQ inspector at the time of inspection and found to be in compliance. 28 The following records are kept: VOC control device efficiency, for life of the equipment Manufacturer operating and maintenance instructions for VOC control devices, for life of the equipment AVO inspections of the VOC control device(s), associated equipment and any repairs, for 3 years. [R307-508-4] In Compliance. These records were observed by DAQ inspector at the time of inspection and found to be in compliance. 29 Leak Detection and Repair 30 The source has an emissions monitoring plan. [R307-509-4(1)(a)] In Compliance. These records were observed by DAQ inspector at the time of inspection and found to be in compliance. 31 The monitoring plan addresses difficult-to-monitor and unsafe-to-monitor components. [R307-509-4(1)(b)] In Compliance. These records were observed by DAQ inspector at the time of inspection and found to be in compliance. 32 If emissions control is required, monitoring surveys are conducted to observe each fugitive emissions component for fugitive emissions. [R307-509-4(1)(c)] In Compliance. These records were observed by DAQ inspector at the time of inspection and found to be in compliance. 33 Initial monitoring surveys were within 60 days after startup for new sources. Subsequent surveys are semi-annual for regular components, annual for difficult-to-monitor components, and as required by the monitoring plan for unsafe-to-monitor components. [R307-509-4(1)(d)] Not Observed. 34 Monitoring surveys are done with OGI equipment or by Method 21. [R307-509-4(1)(e)] In Compliance. Monitoring surveys are done using OGI equipment. 35 Fugitive leaks are repaired within 15 days unless infeasible, unsafe, etc., as stated in the rule, which require repair within 24 months per the rule. [R307-509-4(1)(f)] In Compliance. These records were observed by DAQ inspector at the time of inspection and found to be in compliance. 5 36 Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] In Compliance. These records were observed by DAQ inspector at the time of inspection and found to be in compliance. 37 The following records are kept: The emissions monitoring plan, for life of the site LDAR inspections, repairs and resurveys, for 3 years [R307-509-5] In Compliance. These records were observed by DAQ inspector at the time of inspection and found to be in compliance. 38 Natural Gas Engines 39 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. 40 Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)] In Compliance. These records were observed by DAQ inspector at the time of inspection and found to be in compliance. 41 Affected engine exhaust vents are vertical and unrestricted. Stacks are 8' or greater if the site horsepower rating is 151 to 305 Stacks are 10' or greater if the site horse power rating is 306 or greater. [R307-510-4(3)] In Compliance. 42 Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. These records were observed by DAQ inspector at the time of inspection and found to be in compliance. 6 43 Associated Gas Flaring 44 Associated gas is routed to a process unit for combustion, a sales pipeline or an operating VOC control device, except in an emergency. An emergency release is unanticipated, temporary, infrequent, unavoidable, =24 hrs. and is not due to operator negligence. Low pressure gas from working loss, breathing loss and oil flashing is not "associated gas". [R307-511-4(1)] In Compliance. Associated gas found properly routed at the time of inspection. 45 The following records are kept: The time and date of event Volume of emissions Any corrective action taken for 3 years.[R307-511-5(1)(a)(b)] In Compliance. No emergency venting was reported at the time of inspection. 46 Visible Emissions 47 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 observed at the time of inspection. 48 Emission Inventory: 55 An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. Source was brought online after the 2020 emissions inventory and has not been subject to an emissions inventory yet. 56 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 [40 CFR 60 Subpart OOOOa] In Compliance. 57 NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines [40 CFR 60 Subpart JJJJ] In Compliance. 7 59 NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution [40 CFR 60 Subpart OOOO] In Compliance. 60 NSPS (Part 60) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines [40 CFR 60 Subpart ZZZZ] In Compliance. PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to: Karl UT 16-19 4-1 In Compliance - This source was found in compliance at the time of inspection. I recommend keeping the inspection frequency the same. RECOMMENDATION FOR NEXT INSPECTION: This source was found in compliance at the time of inspection. I recommend keeping the inspection frequency the same.