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Home My WebLink AboutDAQ-2024-0073581 DAQC-PBR142300001-24 Site ID 14230 (B1) MEMORANDUM TO: FILE – JAVELIN ENERGY, LLC – Federal 2-28E19E THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Manager FROM: Fred Goodrich, Environmental Scientist DATE: April 4, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: February 27, 2024 SOURCE LOCATION: Federal 2-28E19E Lat: 40.358588 Long: -109.802731 Business Office: 5221 North O'Conner Boulevard, Suite 1100 Irving, TX 75039 SOURCE TYPE: Tank Battery Uintah County API: 4304732849 SOURCE CONTACTS: Brian Shpakoff, Corporate Environmental Contact Phone: 6822092074, Email: bshpakoff@javelinep.com Greg Simms, Local Contact Phone: 903-754-4835, Email: gsimms@javelinep.com Matt Curry, Corporate Environmental Contact Email: mcurry@javelinep.com Zach Bertelli, Corporate Environmental Contact Email: zbertelli@javelinep.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 OOOO. , - 2 SOURCE EVALUATION: Site Type: PBR-Uncontrolled Controlled by flare Site has Line Power DOGM current 12 month rolling production is: 10,516 BBLs. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: General Provisions VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] In Compliance. Associated gas is routed to a sales gathering line. Vessel vent lines route emissions to a combustion device. Tanks all have thief hatches and PRV's that are closed and not leaking. Air pollution control equipment is designed and installed appropriately, maintained and operated to control emissions. [R307-501-4(2)] In Compliance. A combustion device is installed and operating properly. The DAQ looked for design and installation parameters such as: The vessel vent line is sloped away from the inlet of the combustor, a two-phase scrubber is used to separate natural gas liquids or condensates, the combustor has a lit pilot with an auto-ignition device, and the inlet to the combustor is controlled by a pressure regulating device. Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-2] In Compliance. The vent lines are sloped properly. 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. This installation has a Surefire BMS, pressure gauge, fire suppressor, and inlet pressure regulating valve installed. Pneumatic Controllers Continuous bleed natural gas-driven pneumatic controllers are in compliance with 40 CFR 60.5390 or 60.5390a as applicable. Exemptions to tagging and record keeping requirements apply to controllers existing before 12/1/2015. [R307-502-4] In Compliance. This source does not use continuous bleed natural gas-driven pneumatic controllers. Flares Any flare has an operational auto-igniter. [R307-503-4] Not Observed. 3 Tank Truck Loading Truck loading is done by bottom filling or submerged fill pipe [R307-504(1)] Not Observed. 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)] Not Observed. Oil and Gas Industry Registration Requirement The source is registered with the DAQ. [R307-505-3(3)] In Compliance. 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)] In Compliance. Storage Vessels Thief hatches are kept closed and latched. [R307-506-4(1)] Not Observed. 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)] Not Observed. 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. No tanks are uncontrolled or used as an emergency tank. Upon modification, the well site was re-evaluated against the thresholds of R307-506-4(2). [R307-506-4(6)] Not Observed. 4 Records for each of the following are kept for three years: Storage vessel vent system inspections (openings, thief hatches, pressure relief devices, bypasses, etc.), if required Monthly crude oil throughput Emission calculations, actuals and sampling data when used to justify an exemption to storage vessel rules Emergency storage vessel usage (dates used, emptied, and volumes), if not controlled per R307-506-4(2) [R307-506-5] In Compliance. The recordkeeping procedures of the operator, concerning these requirements, are found to be orderly and complete. These records were reviewed at the local office. VOC Control Devices 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. The ECD is a brand of combustor that has been certified by the US EPA. 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. The operator supplied inspection forms for review. These inspections were conducted monthly as required by 40 CFR (60) OOOO and this requirement. The operator indicated on the monthly inspection records that they use the EPA method 22 to detect visible emissions. 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. Leak Detection and Repair The source has an emissions monitoring plan. [R307-509-4(1)(a)] In Compliance. A field wide plan was produced to the DAQ for review during the records portion of the evaluation. The DAQ is not pursuing compliance action if this has not been prepared for each individual source. The monitoring plan addresses difficult-to-monitor and unsafe-to-monitor components. [R307-509-4(1)(b)] In Compliance. Consistent with the Emissions Monitoring Plan requirement for compliance with NSPS (60) OOOO. 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. The records supplied by the operator met the standards required here. 5 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)] 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 and this requirement. Monitoring surveys are done with OGI equipment or by Method 21. [R307-509-4(1)(e)] In Compliance. The operator uses a Flir GF 320 OGI camera. 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. The supplied inspection forms showed that the latest surveys did not find any leaks. Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] In Compliance. 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. Associated Gas Flaring 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)] Not Observed. 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 reported venting events or breakdowns. 6 Visible Emissions 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] Not Observed. Emission Inventory: An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. The operator submitted for the 2020 emissions inventory. NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution [40 CFR 60 Subpart OOOO] In Compliance. This well was drilled prior to 2011 and is not subject to this subpart. PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Federal 2-28E19E: In Compliance - Inclement weather conditions restricted access to the physical location and were outside of reliable detection parameters for the use of an OGI camera. The DAQ only conducted a review of the rules requiring recordkeeping. The operator's representatives were pleasant and cooperative. Requested records were provided in a timely manner and reviewed at the local field office. RECOMMENDATION FOR NEXT INSPECTION: The DAQ has no recommendations for the next inspector other than what are customary. The DAQ recommends coming back soon, as weather conditions did not permit access. The DAQ was joined by Javelin personnel during the site inspection. ATTACHMENTS: None.