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Home My WebLink AboutDAQ-2024-0079221 DAQC-PBR157610002-24 Site ID 15761 (B1) MEMORANDUM TO: FILE – ALTAMONT ENERGY OPERATING, LLC – Mecca 2-8A2 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Fred Goodrich, Environmental Scientist DATE: May 2, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: April 25, 2024 SOURCE LOCATION: Mecca 2-8A2 Lat:40.404685 Long: -110.12669 Business Office: ORA-01422: exact fetch returns more than requested number of rows 8490 East Crescent Parkway, Suite 100 Greenwood Village, CO 80111 SOURCE TYPE: Tank Battery Duchesne County API: 4301331231 SOURCE CONTACTS: Charles Duncun, Corporate Environmental Contact Email: JensenC@AyresAssociates.com Charles Jensen, Corporate Environmental Contact Phone: 970-309-1022, Email: JensenC@AyresAssociates.com Jesse Duncun, Local Contact Email: jduncan@altamontenergy.com OPERATING STATUS: Operating PROCESS DESCRIPTION: Oil and gas products are brought to the surface by Rotoflex pump. 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. , - 2 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. SOURCE EVALUATION: Site Type: PBR- Controlled Controlled by flare Site powered by Electrical The source registered: 18084 Estimated Oil BBL. DOGM current 12 month rolling production is: 9,606 BBLs. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Engine - No info Provided No info Provided, Pneumatic, Tank General Provisions VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] In Compliance. DAQ observed and appears to meet these requirements. Air pollution control equipment is designed and installed appropriately, maintained and operated to control emissions. [R307-501-4(2)] In Compliance. Appeared to DAQ all components are installed correctly and engineered to design. Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-2] In Compliance. Appeared to DAQ that lines are sloped correctly for liquid removal to scrubber vessel. Flare inlet lines are equipped with a fire arrestor, pressure gauge, inlet pressure regulating valve and other components according to the engineering design, the manufacturers specifications or good practices for safety and emissions control. [R307-501-2] In Compliance. Appeared to DAQ all components are installed correctly and engineered to design. Pneumatic Controllers 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 controllers as described in 40 CFR 60.5365(d)(1). 3 Flares Any flare has an operational auto-igniter. [R307-503-4] In Compliance. Auto Igniter in place and operating as designed. Tank Truck Loading Truck loading is done by bottom filling or submerged fill pipe [R307-504(1)] In Compliance. The truck loading valves are designed for submerged loading and it is routine for truck drivers to load this way. A vapor capture line is used during truck loading if subject to storage vessel emissions controls of R307-506-4(2). Effective 7/1/2019 for sources existing before 1/1/2018, and upon construction for new sources. [R307-504-4(2)] In Compliance. In place and appears operational. Oil and Gas Industry Registration Requirement The source is registered with the DAQ. [R307-505-3(3)] In Compliance. 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. Storage Vessels Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. All hatches were found closed at the start of the evaluation. VOCs from storage vessels are recycled, recovered or controlled by a device that is compliant with R307-508. Exempt if <8000 bbls crude oil per year, <2000 bbls condensate, or if uncontrolled emissions are <4 tons VOC per year. [R307-506-4(2)(a)] In Compliance. Tank emissions are routed to an enclosed combustor. Upon modification, the well site was re-evaluated against the thresholds of R307-506-4(2). [R307-506-4(6)] In Compliance. 4 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 is found to be orderly and complete. These records were reviewed at the local office. VOC Control Devices The VOC control device(s) required by R307-506 or R307-507 has a control efficiency of 95% or greater, operates with no visible emissions and has an operational auto-igniter according to R307-503. [R307-508-3(1)] In Compliance. Combustor operating correctly with no observed Opacity. Monthly AVO inspections are conducted on VOC control devices and associated equipment, and corrective actions are taken within 15 days. [R307-508-3(3)] In Compliance. The Operator supplied inspection forms for review. These inspections were conducted monthly as required by 40 CFR (60) OOOO and this requirement. The Operator indicated on the monthly inspection records that they use the EPA method 22. The following records are kept: VOC control device efficiency, for life of the equipment Manufacturer operating and maintenance instructions for VOC control devices, for life of the equipment AVO inspections of the VOC control device(s), associated equipment and any repairs, for 3 years. [R307-508-4] In Compliance. The recordkeeping procedures of the Operator is found to be orderly and complete. These records were reviewed at the local office. Leak Detection and Repair The source has an emissions monitoring plan. [R307-509-4(1)(a)] In Compliance. Requirement consistent with the Emissions Monitoring Plan required for compliance with NSPS (60) OOOO. 5 The monitoring plan addresses difficult-to-monitor and unsafe-to-monitor components. [R307-509-4(1)(b)] In Compliance. The records supplied by the Operator met the standards required here. If emissions control is required, monitoring surveys are conducted to observe each fugitive emissions component for fugitive emissions. [R307-509-4(1)(c)] In Compliance. The records supplied by the Operator met the standards required here. Initial monitoring surveys were within 60 days after startup for new sources. Subsequent surveys are semi-annual for regular components, annual for difficult-to-monitor components, and as required by the monitoring plan for unsafe-to-monitor components. [R307-509-4(1)(d)] 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 seven months apart, as required by 40 CFR (60) OOOO and this requirement. Monitoring surveys are done with OGI equipment or by Method 21. [R307-509-4(1)(e)] In Compliance. The Operator uses a Flir GF 320 OGI camera. Fugitive leaks are repaired within 15 days unless infeasible, unsafe, etc., as stated in the rule, which require repair within 24 months per the rule. [R307-509-4(1)(f)] In Compliance. The Operator records appear that repairs are made in a timely manner. Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] In Compliance. Operators records are Compliant. The following records are kept: The emissions monitoring plan, for life of the site LDAR inspections, repairs and resurveys, for 3 years [R307-509-5] In Compliance. Record search appears compliant. Associated Gas Flaring Associated gas is routed to a process unit for combustion, a sales pipeline or an operating VOC control device, except in an emergency. An emergency release is unanticipated, temporary, infrequent, unavoidable, =24 hrs. and is not due to operator negligence. Low pressure gas from working loss, breathing loss and oil flashing is not "associated gas." [R307-511-4(1)] In Compliance. No reported venting events or breakdowns. 6 The following records are kept: The time and date of event Volume of emissions Any corrective action taken for 3 years. [R307-511-5(1)(a)(b)] In Compliance. Operator records appear in order. Visible Emissions 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. Well-site is electrified. No visible emissions were detected. Emission Inventory: 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. PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to: Mecca 2-8A2: In Compliance - This source was found to be clean and well-kept with no visible or fugitive emissions. The source was inspected by AVO and with an OGI camera and found to be free of leaks. The Operator's representatives were pleasant and cooperative. Requested records were provided in a timely manner and reviewed at the local field office. RECOMMENDATION FOR NEXT INSPECTION: The DAQ has no Recommendations for the next inspector other than what are customary.