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DAQC-PBR151650001-23
Site ID 15165 (B1)
MEMORANDUM
TO: FILE – OVINTIV USA, INC. – K Moon 2-13-4-3
THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Manager
FROM: Stephen Foulger, Environmental Scientist
DATE: November 27, 2023
SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION
INSPECTION DATE: October 19, 2023
SOURCE LOCATION: K Moon 2-13-4-3
Lat: 40.14067 Long: -110.16756
Business Office:
370 17th Street, Suite 1700
Denver, CO 80202
SOURCE TYPE: Tank Battery
Duchesne County
API: 4301350456
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@ovintv.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
Inventory.
2
SOURCE EVALUATION: Site Type: PBR-Uncontrolled
No Flare Controls
Site powered by engine
The source registered: 7,999 Estimated Oil BBL.
DOGM current 12 month rolling production is: 0.
Utah Statute R307-506 requires a source with throughput
greater than 8,000 BBLs to have controls.
REGISTERED EQUIPMENT: Engine - Engine - Natural Gas 2-Stroke Lean Burn Make - Ajax
Model - E-565 Mfg Year - 2014 Horse Power - 40 Combustion -
natural gas, Pneumatic, Tank
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 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)]
In Compliance. This source was found properly registered at the time of inspection.
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.
23 Upon modification, the well site was re-evaluated against the thresholds of R307-506-4(2).
[R307-506-4(6)]
In Compliance. Combustor was removed after the source dropped below production thresholds.
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. These records were reviewed and found to be compliant at the time of inspection.
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.
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 reviewed and found to be compliant at the time of inspection.
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.
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. Emissions inventory was found properly submitted at the time of inspection.
56
PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.
4
COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to: K Moon 2-13-4-3:
Out of Compliance - The source was found non-compliant at the
time of inspection. This source is uncontrolled and has dropped
below production thresholds. Recommend to keep inspection
frequency the same.
RECOMMENDATION FOR
NEXT INSPECTION: The source was found non-compliant at the time of inspection.
This source is uncontrolled and has dropped below production
thresholds. Recommend to keep inspection frequency the same.
ATTACHMENTS: