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Home My WebLink AboutDAQ-2024-0041671 DAQC-PBR151340001-23 Site ID 15134 (B1) MEMORANDUM TO: FILE – OVINTIV USA INC. – Tomlin 4-6-3-1WH THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Fred Goodrich, Environmental Scientist DATE: October 30, 2023 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: September 28, 2023 SOURCE LOCATION: Tomlin 4-6-3-1WH Lat: 40.25737 Long: -110.04372 Business Office: 370 17th Street, Suite 1700 Denver, CO 80202 SOURCE TYPE: Tank Battery Duchesne County API: 4301351861 SOURCE CONTACTS: Brad Rowser, Local Contact Phone: 435-646-4870, Email: brad.rowser@ovintiv.com Jeanette Liang, Corporate Environmental Contact Phone: 303-248-6822, Email: jeanette.liang@ovintiv.com OPERATING STATUS: Temporarily down 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 Voluntarily controlled by flare Site powered by line. The source registered: 20,000 Estimated Oil BBL. DOGM current 12 month rolling production is: 4,006 BBLs. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Pneumatic, Tank 8 Pneumatic Controllers 9 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 December 1, 2015. [R307-502-4] In Compliance. This source does not use continuous bleed controllers as described in 40 CFR 60.5365(d)(1). 15 Oil and Gas Industry Registration Requirement 16 The source is registered with the DAQ. [R307-505-3(3)] In Compliance. 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)] In Compliance. 18 Storage Vessels 19 Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. All hatches were found closed at the start of the evaluation. 23 Upon modification, the well site was re-evaluated against the thresholds of R307-506-4(2). [R307-506-4(6)] In Compliance. The DAQ did not identify any modifications or unauthorized equipment. 24 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 are found to be orderly and complete. These records were reviewed at the local office. 3 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. Well-site is electrified by local power supplier. No internal combustion engines present. 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] Out of Compliance. Visible emissions were detected from VOC Combustor. The Ovintiv field team corrected immediately. 55 Emission Inventory: 56 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. 60 NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution [40 CFR 60 Subpart OOOO] In Compliance. PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to: Tomlin 4-6-3-1WH: Out of Compliance. Opacity was observed coming from the Well-site Combustor. Upon further investigation with the Ovintiv local regulatory team, it was determined that the combustor was being overrun from liquids from a work-over rig that was performing down hole repair work on the Tomlin 4-6-3-1. Ovintiv immediately corrected the situation and cleared up combustor emissions. No further action was taken due to voluntarily controlled. 4 RECOMMENDATION FOR NEXT INSPECTION: The DAQ recommends frequency of inspections remain current as scheduled with enhanced AVO observance. ATTACHMENTS: None.