DAQ-2024-011439

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DAQC-PBR101616001-24
Site ID 101616 (B1)
MEMORANDUM

TO: FILE – OVINTIV USA INC – Ute Tribal Abbott 13-30

THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Manager

FROM: Stephen Foulger, Environmental Scientist

DATE: October 28, 2024

SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION

INSPECTION DATE: July 29, 2024

SOURCE LOCATION: Lat: 40.08699 Long: -110.27251

Business Office:
Ovintiv USA Inc.
370 17th Street, Suite 1700
Denver, CO 80202

SOURCE TYPE: Tank Battery
Duchesne
API: 4301354230, 4301354231, 4301354232, 4301354233

SOURCE CONTACTS: Brandon Lithgoe, Local Contact
Phone: [phone], Email: [e-mail]
Ryan Zillner, Local Contact
Phone: [phone], Email: [e-mail]

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. Federal Subpart: 40 CFR 60 Subpart JJJJ, 40 CFR
60 Subpart OOOO.

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SOURCE EVALUATION: Site Type: PBR-Controlled
Controlled by flare, Site powered by Engine. The source
registered: 1,500,000 Estimated Oil BBL.
DOGM current 12 month rolling production is: 359,034.
Utah Statute R307-506 requires a source with throughput
greater than 8,000 BBLs to have controls.

REGISTERED EQUIPMENT: Pneumatic, Tank
Visible Emissions Visible emissions are within the following opacity limits: VOC Control Devices and Gasoline engines 0%, Diesel engines 20%, Natural Gas Engines and Boilers, Treater burners & Tank burners 10%, Mobile source dust 10%. [ R307-201-3] In Compliance. No visible emissions were observed at the time of inspection. VOC emissions are, at all times, minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] Out of Compliance. Emissions found coming from an unlit flare and separator combustor. A one-inch gas supply line to tank back combustor was also found leaking at the time of inspection. Flares Any flare has an operational auto-igniter and a continuously burning pilot flame. [R307-503-4] Out of Compliance. Auto-igniter found in non-operational condition at the time of inspection. 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. [R307-501-4(1)]] In Compliance. Flare inlet found properly engineered at the time of inspection. Tank Truck Loading Truck loading is done by bottom filling or submerged fill pipe [R307-504(1)] In Compliance. Truck loading done by bottom or submerged filling at the time of inspection. A vapor capture line is used during truck loading if subject to storage vessel emissions controls of R307-506-4(2). [R307-504-4(2)] In Compliance. Vapor capture lines found available for use at the time of inspection. Storage Vessels Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. Thief hatches found closed and latched at the time of inspection. 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. VOCs found properly routed at the time of inspection.
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Combustors and VOC Control Devices:
Air pollution control equipment is installed appropriately, maintained and operated, pursuant to the
manufacturers specifications, to control emissions. [R307-501-4(2)]
Out of Compliance. Emissions found coming from an unlit flare and separator combustor. A
one-inch gas supply line to tank back combustor was also found leaking at the time of inspection.
Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber).
[R307-501-4(2)]
In Compliance. Vessel vent lines found properly sloped at the time of inspection.
The VOC control device(s) required by R307-506 has a control efficiency of 95% or greater, and
operates with no visible emissions. [R307-508-3(1)]

Out of Compliance. VOC control device found in non-working order at the time of inspection.

Natural Gas Engines

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.

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. Associated gas found properly routed at the time of inspection.

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. No events were reported at the time of inspection.

Emission Inventory:

An emissions inventory has been submitted within the past three years. [R307-150-9(1)]

In Compliance. This is a new source and has not been subject to an emissions inventory.

Leak Detection and Repair:

The source has a source specific emissions monitoring plan. [R307-509-4(1)(a)]

In Compliance. These records were reviewed and found to be compliant at the time of inspection.

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The monitoring plan addresses difficult-to-monitor and unsafe-to-monitor components. [R307-509-4(1)(b)]

In Compliance. These records were reviewed and found to be compliant at the time of inspection.
Monitoring surveys are conducted to observe each fugitive emissions component for fugitive emissions.
[R307-509-4(1)(c)]
In Compliance. These records were reviewed and found to be compliant at the time of inspection.
Initial monitoring surveys were within 60 days after startup for new sources. Subsequent surveys are
semi-annual (no further than 7 months nor nearer than 4 months apart) 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. These records were reviewed and found to be compliant at the time of inspection.

Monitoring surveys are done with OGI equipment or by Method 21. [R307-509-4(1)(e)]

In Compliance. Monitoring is conducted using OGI equipment.

Fugitive leaks are attempted within 5 days and 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. Fugitive leaks found repaired in proper time frame.

Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)]

In Compliance. Resurvey of repaired components completed in proper time frame.

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. These records were reviewed and found to be compliant at the time of inspection.

Oil and Gas Industry Registration Requirement

The source is registered with the DAQ. [R307-505-3(3)]

In Compliance. Source found properly registered at the time of inspection.

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. Source found properly registered at the time of inspection.

Engines subject to R307-510 shall be certified or have an initial performance test per CFR 60.4244.
[R307-510-4(2)]

In Compliance. These records were reviewed and found to be compliant at the time of inspection.

Engine certifications or initial performance tests required are kept for the life of the engine at the source.
[R307-510-5]

In Compliance. These records were reviewed and found to be compliant at the time of inspection.

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Engines that were installed, relocated or modified after January 1, 2016 are required to show compliance with Table 1 of R307-510-4 through a performance test evaluation that is reviewed by the DAQ and
found to be in compliance. [R307-510-4(1)]
In Compliance.

Records for each of the following are kept for three years: Monthly storage vessel vent system inspections (openings, thief hatches, pressure relief
devices, bypasses, etc.), if controlled.
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. [R307-506-5]

In Compliance. These records were reviewed and found to be compliant at the time of inspection.

Monthly AVO and USEPA method 22 inspections are conducted on VOC control devices and associated
equipment, and corrective actions are taken within 5 days and completed within 15 days.
[R307-508-3(3)]

In Compliance. These records were reviewed and found to be compliant at the time of inspection.

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 and USEPA method 22 inspections of the VOC control device(s), associated equipment
and any repairs, for 3 years.
[R307-508-4]

In Compliance. These records were reviewed and found to be compliant at the time of inspection.

NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion
Engines [40 CFR 60 Subpart JJJJ]

In Compliance.

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 the site, the overall status is: Out of Compliance.
Several emissions sources were detected. A compliance advisory
and NFA were sent after appropriate measures were taken to
correct found emissions.

ATTACHMENTS: Compliance Advisory, CA Response, NFA.

August 8, 2024 Sent Via Email: [e-mail] Rik Ombach, Manager Minor Source Oil and Gas Compliance Section
Utah Division of Air Quality P.O. Box 144820 Salt Lake City, UT 84116-4820

RE: Ovintiv USA Inc. Compliance Advisory, DAQC-CA101616001-24 Site ID 101616 (B1) Duchesne County, UT
Dear Mr. Ombach,

Ovintiv USA Inc. (“Ovintiv”) is submitting the below response to the Utah Division of Air Quality (“UDAQ”) Compliance Advisory received via Certified Mail on August 8, 2024.
UDAQ Compliance Advisory:
Potential Violation(s)
On June 27, 2024, Stephen Foulger, an inspector from the DAQ, conducted an inspection at Ovintiv USA Inc. – Ute Tribal Abbott 13-30 located remotely with the latitude and longitude of
40.18699, -110.27251; Duchesne County, Utah.
At the time of the inspection, the DAQ documented the following potential violation:
Requirement and Rule Comments and Observations
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 operation auto-igniter according to R307-503. [R307-508-3(1)]
Out of Compliance: VOC control device found in non-working order at the time of inspection.
Any flare has an operational auto-igniter. [R307-503-4] Out of Compliance: Auto-igniter found in non-working condition at the time of inspection.
VOC emissions are minimized as reasonably
practicable by equipment design,
maintenance, and operation practices. [R307-501-4(1)]
Out of Compliance: Emissions found coming
from an unlit flare and separator burner. A
one-inch gas supply to tank back burner was also found leaking at the time of inspection.
Air pollution control equipment is designed and installed appropriately, maintained, and
operated to control emissions. [R307-501-4(2)]
Out of Compliance: Emissions found coming from an unlit flare and separator burner. A
one-inch gas supply to tank back burner was also found leaking at the time of inspection.
Ovintiv Response: Ovintiv reviewed the Ute Tribal Abbott 13-30 facility and the observations made by the UDAQ inspector. On June 27, 2024 (same day as UDAQ inspection), Ovintiv promptly dispatched an

LDAR Operator to inspect the Ute Tribal Abbott 13-30 using an OGI camera. The LDAR Operator observed fugitive emissions from the separator burner and the one-inch gas supply line to a tank burner. Both leaks were repaired on June 27, 2024, by re-lighting the separator burner and tightening a hammer union on the one-inch gas supply line to the tank burner. After the repairs were completed, the LDAR Operator inspected the repaired components using the OGI camera and confirmed they were no longer leaking.
Upon discovery of the flare pilot being out, the LDAR Operator re-lit the pilot immediately. If you have any questions, please contact me at [phone] or by email at
[e-mail].

Sincerely,

Ryan Zillner
Senior Air Quality Engineer

cc: Stephen Foulger, [e-mail]

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
DAQC-829-24
Site ID 101616 (B1)

Ryan Zillner
Ovintiv USA Inc.
370 17th Street, Suite 1700
Denver, CO 80202

Dear Mr. Zillner,

Re: Compliance Advisory, No Further Action – Ute Tribal Abbott 13-30 Tank Battery,
Duchesne County

On August 1, 2024, the Utah Division of Air Quality (DAQ) sent Ovintiv USA Inc. a Compliance
Advisory (DAQC-CA101616001-24) for potential violations of the Utah Air Quality Rules. A
written response to the compliance advisory was received on August 8, 2024. UDAQ recommends
that no further action is required at this time. Please be aware that closure of this Compliance
Advisory does not constitute a bar to enforcement action for conditions found during other
inspections.

Thank you for your cooperation in resolving this matter. If you have any questions regarding this
letter, please contact me at [phone] or at [e-mail].

Sincerely,

Rik Ombach, Manager
Minor Source Oil and Gas Compliance Section

RO:SF:rh

cc: TriCounty Health Department

August 21, 2024