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HomeMy WebLinkAboutDAQ-2024-0045671 DAQC-CI148960001-23 Site ID 14896 (B1) MEMORANDUM TO: FILE – JAVELIN ENERGY LLC – Wilson 1-18C4 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Chris Jensen, Environmental Scientist DATE: May 2, 2023 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Duchesne County INSPECTION DATE: April 26, 2023 SOURCE LOCATION: Lat 40.22461, Lon -110.37361 Rural Duchesne County SOURCE CONTACTS: Matt Curry, Lead OOOO(a) Technician Cell 435-823-1449 mcurry@javelinep.com OPERATING STATUS: Operating PROCESS DESCRIPTION: Oil and gas products are brought to the surface using a Rotoflex 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-AN148960001-15, dated March 18, 2015 NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution Utah Area Source Rules R307-501 through R307-504 SOURCE EVALUATION: Name of Permittee: Permitted Location: Javelin Energy LLC - Wilson 1-18C4 Production Tank Battery 5221 North O'Conner Boulevard., Suite 1100 NENE ¼ Sec 18 T3S R4W UBSM Irving, TX 75039 Duchesne County, UT SIC Code: 1311: (Crude Petroleum & Natural Gas) ) 0 2 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: Not Applicable. 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. The vapor control system has had some upgrades. These are positive and improve the operation of the combustor. 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 of Javelin Energy is found to be orderly and complete. All requested records were made available to the DAQ in a timely manner. 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: Out of Compliance. A survey with an OGI camera returned fugitive emissions from the thief hatch on the produced water storage tank, from the oil dump pneumatic control, and a stainless fitting on the water dump valve in the treater shed. These last components were marked by a ribbon indicating to the DAQ that these leaks were previously known and not repaired. The most recent LDAR did not list any of these leaking components. I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] Status: Not Applicable. This Approval Order does not limit emissions, only production. Breakdown events must exceed the emissions limits to meet the definition. This cannot be evaluated. 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. 3 Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Wilson 1-18C4 Production Tank Battery II.A.2 Electric Driven Pumpjack(s)** **For informational purpose only II.A.3 Boilers & Heaters Includes: heater/treaters, separators, and other natural gas fired process equipment Maximum Total Capacity: 4.5 MMBtu/hr combined Fuel: Natural Gas II.A.4 Oil Storage Tanks/Overflow Tanks Maximum Total Capacity: 1,850 barrels (combined) II.A.5 One (1) Combustor/Flare II.A.6 Produced Water Storage Tank Capacity: 600 barrels II.A.7 Truck Loading Operations II.A.8 Miscellaneous Storage Tanks Storage of motor oil, methanol, glycol, etc. Maximum Total Capacity: 1,025 gallons (combined) 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. 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. See attachments. 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. EPA Method 9 was used by the DAQ for opacity measurements and none 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. 4 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. 6,068 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. 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. The truck loading area is suitable for submerged loading and it is routine for truck drivers to load this way. II.B.2.c 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.2.d 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.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. Tank emissions are routed to an enclosed combustor. The DAQ evaluates the following parameters for a properly installed vapor control system: An auto- ignition source for the pilot, a lit pilot, proper slope of the vessel vent line to a 2- phase separator, and a pressure control valve to insure proper operating pressures. II.B.3.b The combustor/flare shall operate with no visible emissions. [R307-401-8] Status: In Compliance. EPA Method 9 was used by the DAQ for opacity measurements and none were detected. 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 indicated on the supplied inspection records that EPA method 22 is used. 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), 5 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 day 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. 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 in excess of this requirement. 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 valves, 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 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: Not Observed. 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. 6 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. During the October 2022, survey of this source, the combustor was found to not be operating and was repaired and verified as required. 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 records of each component exempt under II.B.4.c 1. Type of component 2. Description of qualifying exemption. [R307-401-8] Status: In Compliance. The records supplied by the operator met the standards required here. 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. 7 NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution Status: In Compliance. This source has an Approval Order from the State of Utah with legal and enforceable limits. This source is exempt from OOOO for storage vessel affected facilities. A monitoring, repair, and record keeping program is in place that would satisfy the requirements of 40 CFR (60) OOOO for the collection of fugitive emissions components, closed vent system, and storage vessel facilities. See above evaluations. There are not other affected facilities installed. While the thief hatch was found leaking, enforcement action will be taken under the Utah statutes as evaluated in Section 1 of this Approval Order and in R307-501: General Provisions of Utah Administrative Code AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Oil and Gas Industry: General Provisions [R307-501] Status: Out of Compliance. The maintenance or operation is in question as several leaks were found with an OGI camera. The leaking components were tagged with a ribbon suggesting to the DAQ that these components were previously found to be leaking and not repaired. Oil and Gas Industry: Pneumatic Controllers. [R307-502] Status: Not Applicable. 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. 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. 8 EMISSION INVENTORY: Listed before are the Actual Emissions Inventory provided from Javelin Energy LLC - Wilson 1-18C4. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN148960001-15, dated March 18, 2015, is provided. (PTE) are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 3068.00 Not reported Carbon Monoxide 4.78 0.34 Nitrogen Oxides 2.27 0.41 Particulate Matter - PM10 0.12 0.03 Particulate Matter - PM2.5 0.12 0.03 Sulfur Oxides 0.01 0.00 Volatile Organic Compounds 8.04 6.49 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN148960001-15, dated March 18, 2015: Not in Compliance. The source was inspected by AVO and with an OGI camera and the DAQ found fugitive emissions from the thief hatch on the produced water tank, and from a stainless-steel fitting to a control component in the treater shed. Requested records were provided in a timely manner and reviewed at the Altamont field office. The DAQ recommends that Javelin Energy answer to a Compliance Advisory HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: The DAQ has no recommendations for the next inspector other than what are customary. The DAQ recommends the inspection frequency of this source remain as planned. ATTACHMENTS: Applicable Supporting Documentation Included Javelin Energy Partners Management LLC 5221 N O’Connor Blvd., #1100 Irving, TX 75039 Main: (469) 575-3800 February 21, 2023 Utah Division of Air Quality Attn: Mr. Chris Jensen, CES Environmental Scientist III Vernal, Utah 84078 RE: AO State-Wide Requirements Dear Mr. Jensen: In accordance with the State-Wide Requirements as listed in the Approval Orders, this letter is to inform you that wells on the attached list were in production before EP Energy (Now operating as Javelin Energy Partners Management, LLC) had been issued the Approval Orders. The Completion Date of each well is listed on the attached list for you to reference. If you have any further questions, please feel free to contact me at your convenience using the phone number and/or email address below. Very truly yours, Mandie Crozier Javelin Energy Partners Management LLC| Sr. Regulatory Specialist (435) 401-8335 | MCrozier@JavelinEP.com AO Permit Facility Name Completion Date Lat Long N149530003 Young 3‐15A3 5/4/2016 40.392396 ‐110.201327 N149660002 Stevenson 2‐25A5 6/5/2017 40.361661 ‐110.391564 N148270001 Lake Fork Ranch 3‐10B4 4/29/2012 40.31965 ‐110.315472 N148310002 Lake Fork Ranch 4‐14B4 7/24/2012 40.312614 ‐110.310917 N145370002 Freeman 4‐16B4 10/5/2011 40.30353285 ‐110.3403809 N145220002 El Paso 4‐21B4 12/29/2011 40.28913844 ‐110.3376385 N148330002 Lake Fork Ranch 4‐23B4 1/28/2012 40.288938 ‐110.298993 N148340002 Lake Fork Ranch 4‐24B4 6/13/2012 40.289393 ‐110.277777 N145380001 Brotherson 1‐25 2‐25B4 3/2/1983 40.28370931 ‐110.2808722 N150440001 Spratt 3‐32B4 7/17/2014 40.259286 ‐110.354287 N148390001 Peck 3‐13B5 10/20/2012 40.302423 ‐110.394508 N148110001 Allen 4‐25B5 12/15/2012 40.275148 ‐110.393764 N145300001 Spratt 3‐26B5 3/24/2011 40.27445036 ‐110.4121309 N148410002 Potter 4‐27B5 5/13/2012 40.281065 ‐110.441623 N148190002 El Paso 4‐29B5 9/27/2011 40.273564 ‐110.467268 N149960001 DWR 4‐32B5 12/10/2014 40.260165 ‐110.46682 N145330001 Wilson 3‐36B5 5/28/2011 40.26944704 ‐110.4027181 N148960001 Wilson 1‐1BC4 3/21/2013 40.224616 ‐110.37361 N150660001 Kozar 1‐4C4 4/8/2014 40.254191 ‐110.348692 N148180001 El Paso 3‐5C4 8/25/2012 40.254522 ‐110.367796 N150110001 Duchesne 4‐5C4 6/12/2014 40.24619 ‐110.35686 N148970001 Hewett 2‐6C4 3/29/2013 40.24395 ‐110.373585 N149650001 EP Energy Vasquez 3‐7C4 1/8/2015 40.230238 ‐110.373711 N148220001 Golinski 1‐8C4 1/23/2012 40.2389 ‐110.3662 N149400001 Hislop 3‐8C4 1/16/2014 40.231889 ‐110.356099 N149410001 Ocampo 4‐9C4 11/14/2013 40.240092 ‐110.343995 N150000001 Adelman 5‐9C4 5/1/2015 40.2369 ‐110.33513 N149020001 Moon 1‐14C4 5/21/2013 40.21601 ‐110.296384 N149420001 Thiebaud 2‐14C4 1/26/2014 40.224037 ‐110.296325 N150180002 Jenkins 3‐14C4 4/17/2015 40.22037 ‐110.30712 N150480002 Woodward 4‐14C4 7/4/2015 40.22753 ‐110.30453 N149340001 Ayers Trust 2‐15C4 11/22/2013 40.21658 ‐110.328615 N150700001 Moon 3‐15C4 4/3/2014 40.226031 ‐110.316474 N149980002 Cahal 4‐15C4 8/2/2015 40.22308 ‐110.32805 N150220001 Hogge 3‐16C4 6/18/2014 40.21784 ‐110.3454 N150080001 Chestnut 3‐17C4 4/25/2014 40.224567 ‐110.36623 N149970002 Flying Dutchman 5‐17C4 2/28/2015 40.21632 ‐110.35541 N149380001 Flying Dutchman 3‐18C4 1/13/2014 40.217489 ‐110.373594 N149730002 Duchesne City 3‐19C4 7/16/2015 40.20285 ‐110.38169 N150680002 KT VI Properties 2‐20C4 and EP Energy 8‐20C4 Produ 11/24/2014 40.200632 ‐110.36677 N149570002 Flannery Flannery 3‐20C4 5/6/2015 40.20177 ‐110.3519 N150190002 Fairclough 4‐20C4 10/2/2014 40.208736 ‐110.364297 N150760003 Silver 5‐20C4 7/11/2014 40.208204 ‐110.354537 N150040001 Anderson 2‐21C4 3/19/2015 40.21115 ‐110.34735 N149390001 Flying Dutchman 3‐21C4 2/27/2014 40.202674 ‐110.335661 N149000001 Moore 1‐23C4 5/8/2013 40.201606 ‐110.296698 N149430001 Wollman 2‐23C4 12/13/2013 40.211455 ‐110.30897 N149700001 KRATZER 1‐27C4 12/4/2014 40.197525 ‐110.316384 N149370001 Eugster 2‐28C4 11/2/2013 40.196455 ‐110.347999 N149850002 Karren Trust 4‐30C4 5/15/2015 40.19642 ‐110.37622 N150430002 Moon 3‐31C4 9/17/2015 40.391989 ‐110.241204 N149810002 Poulson 4‐31C4 1/15/2016 40.176279 ‐110.388443 N150290001 Merkley 1‐32C4 3/21/2014 40.18264 ‐110.353687 N150350001 Moon 3‐32C4 8/1/2016 40.170851 ‐110.351274 N150460001 Thomas 1‐33C4 11/23/2015 40.18363 ‐110.34526 N150270001 UDOT 2‐1C5 11/6/2014 40.255174 ‐110.402267 N149950002 Farnsworth 3‐1C5 3/12/2015 40.24726 ‐110.4027 N150360002 Neihart 2‐2C5 10/11/2014 40.244 ‐110.41685 N149940002 Shepard 5‐2C5 6/23/2015 40.24797141 ‐110.4225197 N149790002 Circle B 2‐3C5 6/11/2015 40.2471 ‐110.43935 N149580002 Phillips Trust 3‐3C5 1/8/2016 40.251974 ‐110.432385 N148170001 Duchesne Land 4‐10C5 9/28/2012 40.230028 ‐110.430629 N149440001 Young 1‐12C5 2/20/2014 40.239945 ‐110.393032 N149840002 EP Energy 4‐12C5 4/11/2015 40.232675 ‐110.393144 N149990002 Flying Dutchman 1‐13C5 12/7/2015 40.214414 ‐110.393224 N149780002 Millett 2‐14C5 5/30/2015 40.22525 ‐110.4236 N150230002 White 3‐14C5 8/12/2015 40.21785 ‐110.41439 N148850001 Allison 4‐19C5 1/10/2013 40.20942 ‐110.485726 N148370001 Melesco 4‐20C6 8/8/2012 40.208388 ‐110.59323 N144820002 Ute Fee 2‐33C6 12/14/1985 40.172588 ‐110.574171 N145270001  Hill 3‐24C6 8/12/2011 40.21050154 ‐110.5172226 N150090001 Circle 3 Ranch 2‐6D6 8/7/2014 40.168376 ‐110.613857 N149350001 Brighton 3‐31A1E 2/6/2014 40.348813 ‐109.923763 N143630003 H D Landy 1‐30A1E Production Tank Battery 11/20/1980 40.37058101 ‐109.9279162 N143710002 Lila D 2‐25A1 Production Tank Battery 10/27/1987 40.37281418 ‐109.9375632 N143620002 L Bolton 1‐12A1 Production Tank Battery 5/6/1983 40.4080413 ‐109.9456716 N143680002 Bastian 1‐2A1 Production Tank Battery 1/8/1984 40.42232807 ‐109.9674799 N143610003 Houston 1‐34Z1 Production Tank Battery 7/25/1981 40.44189281 ‐109.9865299 N150490002 White 1‐23C5 8/27/2015 40.21014 ‐110.41326 N149820002 White Trust 3‐23C5 6/24/2015 40.20216 ‐110.42063 N150470001 Van Wyck 2‐24C5 6/9/2014 40.20408 ‐110.3929 N149360001 Duchesne City 2‐25C5 2/15/2014 40.195541 ‐110.390197 N149510002 Moon 3‐25C5 4/2/2015 40.186293 ‐110.392864 N149600001 CARMAN 2‐36C5 12/17/2014 40.179511 ‐110.394898 N142720004 Allen 3‐7B4 3/6/2009 40.326844 ‐110.385368 N145360002 El Paso 3‐21B4 10/11/2011 40.29722894 ‐110.3471842 N154450001 Cornaby 2‐14A2 Tank Battery 8/8/1991 40.399718 ‐110.069603 NSPS OOOOa LDAR Inspection Form Project Name:Utah LDAR Inspections Lat:40.22462 Business Unit:Altamont Long:-110.37361 Facility Name:Wilson 1-18C4 Location: Date of Inspection:10/12/2022 Time of Inspection:           Beginning Time:9:20 Company Contact: Matt Curry   End Time:9:30 Phone Number:435-823-1449 Inspector Information Inspector's Name Kolby Hoover Inspector Training Level:FLIR Certified Inspector's Title Environmental Technician Company:WSP USA Inc. Inspection Information Camera Model:GF 320 Regulatory Requirement OOOOa Daily Verification Check Video:MOV_0009 Inspection Type Semiannual Inspection Method OGI Camera Inspection Status Closed Site Conditions Ambient Temperature (°F)58 Sky Conditions Clear Maximum Wind Speed (mph)2 Calibrations FLIR Calibration Date and Time 10/12/2022 09:00 Max Viewing Distance:  30' Gas:      Propane 4-Gas Meter Calibration Date and Time 10/12/2022 09:00 4-Gas Meter Readings: Summary of leaking components O2 (18%)CO (50 ppm)LEL (50%)H2S (10 ppm) # Leaks 20.9 0 0 0 Valves Connectors Number of Difficult-to-Monitor Components 0 Flanges Number of Unsafe-to-Monitor Components 0 Pressure Regulators Number of Components Not Repaired 0 Pressure Relief Devices (PRD)1 Number of Delay of Repair Components 0 Thief Hatch Any Deviations from Monitoring Plan? No TOTAL:1                          If Yes, Describe:  Leaking Component Details * Describe corrective actions initiated, date completed, and note the person that completed the work in the Corrective Action Log. Leak Tag ID Leak Description Monitoring Method FLIR Video/Photo ID Date of First Repair Attempt Date of Successful Repair Date of Re- monitoring (W/I 15 days) 1 0830 Incinerator not burning.IR - Camera 10/12/22 10/12/22 10/12/22 Is a process unit shutdown required for repair?No Does a part need to be ordered for repair?No Can the component be monitored without being exposed to immediate danger?Yes Is the component buried, insulated, or obstructed by equipment or piping that prevents access?No Can component be monitored without being elevated > 2 meters above a supported surface or can the component be reached with a scissor lift or hydraulic scaffold that allows up to 7.6 meters above ground?Yes Comments Lit incinerator. Verified with IR camera. (10/12/22)