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HomeMy WebLinkAboutDAQ-2024-0046191 DAQC-CI144810001-23 Site ID 14481 (B1) MEMORANDUM TO: FILE – JAVELIN ENERGY, LLC – Lawrence 1-30B4 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Fred Goodrich, Environmental Scientist DATE: December 20, 2023 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Duchesne County INSPECTION DATE: November 30, 2023 SOURCE LOCATION: 40.283412 -110.375491 Duchesne County, UT 84000 DIRECTIONS: SOURCE CONTACTS: OPERATING STATUS: Operating. PROCESS DESCRIPTION: Oil and gas products are brought to the surface using a pumping unit. These products go through a separator where the oil and any water products are sent to storage tanks and the 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: Approval Order (AO) DAQE-AN14481003-15 SOURCE EVALUATION: Name of Permittee: Permitted Location: Javelin Energy LLC - Lawrence 1-30B4 5221 North O'Conner Boulevard, Suite 1100 40.283412 -110.375491 Irving, TX 75039 Duchesne County, UT 84000 SIC Code: 1311: (Crude Petroleum & Natural Gas) Section I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] Status: In Compliance. , - 2 I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] Status: In Compliance. This source did not exceed any of the limits set in the AO. I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] Status: In Compliance. The DAQ did not identify any modifications or unauthorized equipment. I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] Status: In Compliance. The recordkeeping procedures are found to be orderly and complete. All requested records were made available to the DAQ in a timely manner. A records search was not part of this evaluation. I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] Status: In Compliance. The DAQ found all of the installed equipment to be clean and maintained in good repair. The pollution control system components appear to be operated as expected. I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] Status: In Compliance. No breakdowns reported. I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. Emission totals for the criteria pollutants were reported to the 2020 inventory for this source. See table of reported values near the end of the evaluation. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.B Requirements and Limitations II.B.1 Site-Wide Requirements II.B.1.a The owner/operator shall notify the Director in writing when the equipment listed in this AO has been installed and is operational. To ensure proper credit when notifying the Director, send your correspondence to the Director, attn: Compliance Section. 3 If the owner/operator has not notified the Director in writing within 18 months from the date of this AO on the status of the construction and/or installation, the Director shall require documentation of the continuous construction and/or installation of the operation. If a continuous program of construction and/or installation is not proceeding, the Director may revoke the AO. [R307-401-18] Status: In Compliance. Operator had sent a letter last year confirming this information.. II.B.1.b Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any stationary point or fugitive emission source on site to exceed 10 percent opacity. [R307-401-8] Status: In Compliance. No visible emissions were detected. II.B.1.b.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3] Status: In Compliance. The operator indicated on the monthly inspection records that they use the EPA method 22. II.B.2 Tank Requirements II.B.2.a The owner/operator shall not produce more than 102,200 barrels (1 barrel = 42 gallons) of crude oil per rolling 12-month period. [R307-401-8] Status: In Compliance. A search of DOGM records found 5,546 BBLs of crude were produced in the preceding 12-month period. II.B.2.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the twentieth day of each month using data from the previous 12 months. Records of crude oil production shall be kept for all periods when the plant is in operation. Crude oil production shall be determined by process flow meters and/or sales records. [R307-401-8] Status: In Compliance. Records verified. II.B.2.b The owner/operator shall load the tanker trucks on site by the use of submerged loading. [R307-401-8] Status: In Compliance. Wellsite is plumbed for submerged loading and is operational. II.B.2.c The owner/operator shall keep the storage tank thief hatches closed and latched except during tank unloading or other maintenance activities. [R307-401-8] Status: In Compliance. All hatches were found closed at the start of the evaluation. II.B.2.d The owner/operator shall inspect the thief hatches at least once every six months to ensure the thief hatches are closed, latched, and the associated gaskets, if any, are in good working condition. Records of thief hatch inspections shall include the date of the inspection and the status of the thief hatches. [R307-401-8] Status: In Compliance. The operator supplied inspection forms for review. These inspections were conducted monthly as required by 40 CFR (60) OOOO in excess of this requirement. II.B.3 Combustor/Flare Requirements II.B.3.a All exhaust gas/vapors from the oil storage tanks shall be routed to the operating combustor/flare. [R307-401-8] Status: In Compliance. Appeared to be engineered to design. 4 II.B.3.b The combustor/flare shall operate with no visible emissions. [R307-401-8] Status: In Compliance. No opacity observed. II.B.3.b.1 Visual determination of smoke emissions from flares shall be conducted according to 40 CFR 60, Appendix A, Method 22. [R307-401-8] Status: In Compliance. The operator supplied inspection forms for review. These inspections were conducted monthly as required by 40 CFR (60) OOOO in excess of this requirement. II.B.4 Leak Detection and Repair Requirements II.B.4.a The owner/operator shall conduct a leak detection inspection for each valve(s), flange(s) or other connection, pump(s), compressor(s), pressure relief device(s) or other vent(s), process drain(s), open-ended valve(s), pump seal(s), compressor seal(s), and access door seal(s) or other seal containing or contacting a process stream with hydrocarbons that is associated with each of the approved emission unit listed in Section II: Special Provisions. Leak detection inspections shall be conducted according to the following schedule: a. No later than 90 days after startup or 180 days from the date of this AO, and b. At least once every 12 months after the initial leak detection inspection. [R307-401-8] Status: In Compliance. Operator met these requirements. II.B.4.b Inspections shall be conducted in one of two ways; 1. An analyzer that meets U.S. EPA Method 21, 40 CFR Part 60, Appendix A 2. An optical gas imaging instrument as defined in 40 CFR 60.18(g)(4) The optical gas imaging instrument must meet requirements specified in 40 CFR 60.18 (i)(3). Any emissions detected with an optical gas imaging instrument shall be considered a leak in need of repair unless the owner/operator evaluates the leak with an analyzer meeting U.S. EPA Method 21, 40 CFR Part 60 and the analyzer reading is less than 500 ppmv. A reading of 500 ppmv or greater shall be considered a leak in need of repair. Emissions detected from tank gauging, load-out operations, venting of pneumatics, properly operating pressure relief values, or other maintenance activities shall not be considered leaks. [R307-401-8] Status: In Compliance. The operator uses a Flir GF 320 OGI camera. II.B.4.c The owner/operator is exempt from inspecting a valve, flange or other connection, pump or compressor, pressure relief device, process drain, open-ended valve, pump or compressor seal system degassing vent, accumulator vessel vent, agitator seal, or access door seal under any of the following circumstances: a. the contacting process stream only contains glycol, amine, methanol, or produced water, b. monitoring could not occur without elevating the monitoring personnel more than six feet above a supported surface or without the assistance of a wheeled scissor-lift or hydraulic type scaffold, c. monitoring could not occur without exposing monitoring personnel to an immediate danger as a consequence of completing monitoring, or 5 d. the item to be inspected is buried, insulated in a manner that prevents access to the components by a monitor probe, or obstructed by equipment or piping that prevents access to the components by a monitor probe. [R307-401-8] Status: In Compliance. II.B.4.d If a leak is detected at any time, the owner/operator shall attempt to repair the leak no later than 5 calendar days after detection. Repair of the leak shall be completed no later than 15 calendar days after detection, unless parts are unavailable or unless repair is technically infeasible without a shutdown. The owner/operator shall inspect the repaired leak no later than 15 calendar days after the leak was repaired to verify that it is no longer leaking. If replacement parts are unavailable, the replacement parts must be ordered no later than 5 calendar days after detection, and the leak must be repaired no later than 15 calendar days after receipt of the replacement parts. If repair is technically infeasible without a shutdown, the leak must be repaired by the end of the next shutdown. If a shutdown is required to repair a leak, the shutdown must occur no later than 6 months after the detection of the leak unless the owner/operator demonstrates that emissions generated from the shutdown are greater than the fugitive emissions likely to result from delay of repair. [R307-401-8] Status: In Compliance. The supplied inspection forms showed that the latest surveys did not find any leaks. II.B.4.e Records of inspections and leak detection and repair shall include the following: a. The date of the inspection, b. The name of the person conducting the inspection, c. Any component not exempt under II.B.4.c that is not inspected and the reason it was not inspected, d. The identification of any component that was determined to be leaking, e. All records shall be maintained for optical gas imaging instrument as per 40 CFR 60.18(i)(4)(vi) f. The date of first attempt to repair the leaking component, g. Any component with a delayed repair, h. The reason for a delayed repair, 1. For Unavailable Parts: i. The date of ordering a replacement component, ii. The date the replacement component was received, 2. For a Shutdown: i. The reason the repair is technically infeasible, ii. The date of the shutdown iii. Emission estimates of the shutdown and the repair if the delay is longer than 6 months, i. Corrective action taken, j. The date corrective action was completed, and k. The date the component was verified to no longer be leaking. l. The following records of each component exempted under II.B.4.c m. Type of component n. Description of qualifying exemption. [R307-401-8] Status: In Compliance. Observed records at local field office. Section III: APPLICABLE FEDERAL REQUIREMENTS In addition to the requirements of this AO, all applicable provisions of the following federal programs have been found to apply to this installation. This AO in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including UAC R307. 6 AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Oil and Gas Industry: Pneumatic Controllers. [R307-502] Status: In Compliance. This source does not use continuous bleed natural gas-driven pneumatic controllers as described in 40 CFR 60.5365(d)(1). Oil and Gas Industry: Tank Truck Loading [R307-504] Status: In Compliance. In compliance. The truck loading area is suitable for submerged loading and it is routine for truck drivers to load this way. This source is currently exempt from the installation of a vapor capture line by registration with an Approval Order. Oil and Gas Industry: Flares. [R307-503] Status: In Compliance. An enclosed combustor 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. EMISSION INVENTORY: Listed before are the Actual Emissions Inventory provided from Javelin Energy LLC - Lawrence 1-30B4. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN14481003-15, is provided. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 5044.00 Carbon Monoxide 6.16 Nitrogen Oxides 3.91 Particulate Matter - PM10 0.25 Particulate Matter - PM2.5 0.25 Sulfur Oxides 0.02 Volatile Organic Compounds 13.41 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr Benzene (Including Benzene From Gasoline) (CAS #71432) 140 Ethyl Benzene (CAS #100414) 11 Formaldehyde (CAS #50000) 5 Hexane (CAS #110543) 2300 Methanol (CAS #67561) 8 Toluene (CAS #108883) 140 Xylenes (Isomers And Mixture) (CAS #1330207) 60 7 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN14481003-15: In Compliance - This source was found to be clean and well-kept with no visible or fugitive emissions. The source was inspected by AVO and with an OGI camera and found to be free of leaks. The operator's representatives were pleasant and cooperative. Requested records were provided in a timely manner and reviewed at the local field office. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: The DAQ recommends the inspection frequency of this source remain as planned. NSR RECOMMENDATIONS: ATTACHMENTS: None.