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HomeMy WebLinkAboutDAQ-2024-0071141 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: