Loading...
HomeMy WebLinkAboutDAQ-2024-0051371 DAQC-PBR156070001-24 Site ID 15607 (B1) MEMORANDUM TO: FILE – UINTA WAX OPERATING, LLC – Coleman Tribal 1-33-3-1E THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Chris Jensen, Environmental Scientist DATE: February 20, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: February 14, 2024 SOURCE LOCATION: Coleman Tribal 1-33-3-1E Lat:40.184345 Long: -109.882212 Business Office: 5128 Apache Plume Road, Suite 300 Fort Worth, TX 76109 SOURCE TYPE: Tank Battery Uintah County API: 43047-54036 SOURCE CONTACTS: Aimee Cole, Local Contact Phone: 720-384-7365, Email: acole@finleyresources.com Kaylene Bridwell, Corporate Environmental Contact Phone: 405-496-7308, Email: kaylene.bridwell@uintawax.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 Inventories, and 40 CFR 60 Subpart JJJJ. SOURCE EVALUATION: Site Type: PBR- Uncontrolled Voluntarily Controlled by Flare Site powered by Engine 2 DOGM current 12 month rolling production is: 2,494 BBLs. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: None registered. Found an Arrow L-795 pumpjack engine on location. 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 12/1/2015. [R307-502-4] In Compliance. This source does not use continuous bleed natural gas-driven pneumatic controllers. 11 Oil and Gas Industry: General Provisions [R307-501] Out of Compliance. A survey with an OGI camera found several leaking components associated with the treater and tank battery. At the battery there was found a stuck open Kimray T-12 pneumatic control and a leaking Tee block. At the treater there was a leaking Kimray control valve on the sales gas line. 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. None of these recordkeeping requirements are applicable at this source. 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)] Not Applicable. The pumpjack engine was installed prior to 2016 and not subject to these emissions standards but will be evaluated under NSPS (60) JJJJ. See below. 40 Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)] Not Applicable. UWO does not retain records of performance testing longer than 5 years. The well, at this source, was drilled in 2015, and lifetime retention of stack testing does not apply. 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] Not Applicable. A record of an initial performance test was not provided to the DAQ for inspection nor kept by UWO. Engines manufactured before 2008 or installed pre-2016 are not required to maintain a performance test results for life. 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 detected. 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. 4 57 Applicable Federal Regulations: NSPS (Part 60) OOOOa: Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015 [40 CFR 60 Subpart OOOOa] Not Applicable. The tank battery at this source no longer has the production to have the PTE in excess of 4 TPY and are no longer an affected facility under this subpart. There are no other affected facilities installed. 59 NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines [40 CFR 60 Subpart JJJJ] In Compliance. The engine at this source is not certified. Stack testing may or may not have been performed but, the record retention time limit for this testing has expired. The maintenance provisions are met. PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to: Coleman Tribal 1-33-3-1E: Out of Compliance - A survey with an OGI camera revealed several leaking components. The unusually high number of leaks indicates poor operation and maintenance that is not in line with UAC R307-501. In consideration of the joint consent decree with the US EPA, still in negotiation with UWO, no further enforcement action is taken. 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 be reduced. ATTACHMENTS: Email ! c>k A ?, c maiR/ ?20 880.3610 fax 303.292.1562 'all frw. 1.888 693.0020 Crescent Point 555 1/th Street. Stitts 1800 Oeawr, Colorado JSA8020? UTAH DEPARTMENT OF ENVIRONMENTAL QUAUTY JUN I 4 2016 DIVISION OF AIR QUAUTY Subject: Notice of Startup Crescent Point Energy U.S. Corp. 4 Projects June 13, 2016 Director Attn: Compliance Section Utah Department of Environmental Quality 195 North 1950 West Salt Lake City, Utah 84114-4820 Dear Director: This letter serves as a notice of startup of the emission sources at 4 production facilities located in Uintah County, Utah. The list of the 4 production facilities including the corresponding Approval Orders (AO) and location information is attached. Full operation of the equipment, as described in the respective approval orders, has commenced. At each of these sites, produced fluids are pumped from the well using a natural gas-powered engine. The produced fluids are routed to a heater-treater, and from here, the oil phase is directed to atmospheric aboveground storage tanks. The water phase is piped to a separate atmospheric aboveground storage tank. Crude oil and produced water are transferred from the storage tanks to tanker trucks for transportation from the site. Gas from the heater-treater is routed into the fuel line to be used by the heaters and engine as well as being metered and routed to a sales pipeline. Fugitive emissions are emitted from the various components (flanges, connectors, etc.) at the site. Should you have any questions regarding this notice or concerning the facility, please contact me at (303) 382-6768 or via email at cdelhierro@crescentpointenergy.com. Sincerely, Chris Del Hierro Senior HSE Coordinator Attachment: 4 Production Facilities with Corresponding Approval Order and Location Information Document Date 6/3/2016 I www,erescent[jointeiiefgy,cam TSXiCPG DAQ-2016-007786 Notice of Startup Crescent Point Energy Facility Name Latitude Longitude Permit # Coleman Tribal 9-33-3-1E 40.17818 -109.88056 N156090001-16 Coleman Tribal 8-33-3-1E 40.18127 -109.88159 N156080001-16 Coleman Tribal 1-33-3-1E 40.18434 -109.88221 N156070001-16 Deep Creek 4-16-4-2E 40.14153 -109.78045 N156100001-16 UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY JUN I h 2016 DIVISION OF AIR QUALITY Page 1 of 1