The URL can be used to link to this page

Home My WebLink AboutDAQ-2024-0115351 DAQC-CI145450001-24 Site ID 14545 (B1) MEMORANDUM TO: FILE – JAVELIN ENERGY LLC – Killian 3-12A1 THROUGH: Rik Ombach, Minor Source Oil and Gas Section Manager FROM: Fred Goodrich, Environmental Scientist DATE: July 8, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Uintah County INSPECTION DATE: February 27, 2024 SOURCE LOCATION: Lat 40.40561783, Lon -109.93779 Rural Uintah County SOURCE CONTACTS: Matt Curry, Lead LDAR Technician Phone 435-823-1449 OPERATING STATUS: Operating PROCESS DESCRIPTION: Oil and gas products are brought to the surface using a pumping unit. These products go through a separator where the oil and any water products are sent to storage tanks and the 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: Approval Order (AO) DAQE-ADAQE-AN145450001-13-13, dated January 16, 2013 NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution, SOURCE EVALUATION: Name of Permittee: Permitted Location: Javelin Energy LLC - Killian 3-12A1 Production Tank Battery 5221 North O'Conner Boulevard, Suite 1100 NENW ¼ sec 12 T1S R1W UBSM Irving, TX 75039 Uintah County SIC Code: 1311: (Crude Petroleum & Natural Gas) Section I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] , - 2 I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] Status: In Compliance. This source did not exceed any of the limits set in the AO. I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] Status: In Compliance. The DAQ did not identify any modifications or unauthorized equipment. I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] Status: In Compliance. The recordkeeping procedures are found to be orderly and complete. All requested records were made available to the DAQ in a timely manner. I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] Status: In Compliance. The DAQ found all of the installed equipment to be clean and maintained in good repair. The pollution control system components appear to be operated as expected. I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] Status: In Compliance. No breakdowns reported. I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. Emission totals for the criteria pollutants were reported to the 2020 inventory for this source. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Killian 3-12A1 Production Tank Battery II.A.2 Two (2) Oil Storage Tanks Capacity: 21,000 gallons each II.A.3 One (1) Combustor/Flare Maximum Capacity: 3.0 MMBtu/hr II.A.4 One (1) Produced Water Storage Tank Capacity: 21,000 gallons II.A.5 One (1) Emergency Overflow Tank Capacity: 16,800 gallons 3 II.A.6 One (1) Methanol Storage Tank Capacity: 500 gallons II.A.7 One (1) Glycol Storage Tank Capacity: 500 gallons II.A.8 Truck Loading Operations II.A.9 Various Boilers/Heaters Rated Capacity: 4.5 MMBtu/hr combined II.A.10 One (1) Electric Pumpjack - listed for informational purposes only - II.A.11 One (1) Oil/Water Separator - listed for informational purposes only - II.B Requirements and Limitations II.B.1 The Killian 3-12A1 Crude Oil and Natural Gas Production Tank Battery shall be subject to the following: II.B.1.a The owner/operator shall notify the Director in writing when the equipment listed in this AO has been installed and is operational. To ensure proper credit when notifying the Director, send your correspondence to the Director, attn: Compliance Section. If the owner/operator has not notified the Director in writing within 18 months from the date of this AO on the status of the construction and/or installation, the Director shall require documentation of the continuous construction and/or installation of the operation. If a continuous program of construction and/or installation is not proceeding, the Director may revoke the AO. [R307-401-18] Status: In Compliance. Found in files. II.B.1.b The owner/operator shall not exceed 2,688,000 gallons (42 gallons = 1 barrel) of crude oil throughput per rolling 12-month period. [R307-401-8] Status: In Compliance. A search of DOGM records found 18,221 BBLs of crude were produced in the preceding 12-month period. II.B.1.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the twentieth day of each month using data from the previous 12 months. Records of crude oil throughput shall be kept for all periods when the plant is in operation. Crude oil throughput shall be determined by company and/or customer billing records. The records of crude oil throughput shall be kept on a daily basis. [R307-401-8] Status: In Compliance. II.B.1.c Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any stationary point or fugitive emission source on site to exceed 10 percent opacity. [R307-401-8] Status: In Compliance. No visible emissions were detected. II.B.1.c.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3] Status: In Compliance. The DAQ used the EPA Method 9 to detect visible emissions. 4 II.B.1.d The owner/operator shall load the tanker trucks on site by the use of submerged loading. [R307-401-8] Status: In Compliance. The truck loading area is suitable for submerged loading and it is routine for truck drivers to load this way. II.B.1.e The owner/operator shall keep the storage tank thief hatches closed and latched except during tank unloading or other maintenance activities. [R307-401-8] Status: In Compliance. All hatches were found closed at the start of the evaluation. II.B.1.e.1 The owner/operator shall inspect the thief hatches at least once every six months to ensure the thief hatches are closed, latched, and the associated gaskets, if any, are in good working condition. Records of thief hatch inspections shall include the date of the inspection and the status of the thief hatches. [R307-401-8] Status: In Compliance. The records supplied by the operator met the standards required here. Requirement consistent with the Emissions Monitoring Plan required for compliance with NSPS (60) OOOO. II.B.2 The combustor/flare shall be subject to the following: II.B.2.a All exhaust gas/vapors from the oil storage tanks shall be routed to the operating combustor/flare. [R307-401-8] Status: In Compliance. Tank emissions are routed to an enclosed combustor. II.B.2.b The combustor/flare shall operate with no visible emissions. [R307-401-8] Status: In Compliance. No visible emissions were detected. II.B.2.b.1 Visual determination of smoke emissions from flares shall be conducted according to 40 CFR 60, Appendix A, Method 22. [R307-401-8] Status: In Compliance. The operator indicated on the monthly inspection records that they use the EPA method 22. Section III: APPLICABLE FEDERAL REQUIREMENTS In addition to the requirements of this AO, all applicable provisions of the following federal programs have been found to apply to this installation. This AO in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including UAC R307. NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution Status: In Compliance. This source has an Approval Order from the State of Utah with legal and enforceable limits. A monitoring, repair, and record keeping program is in place that would satisfy the requirements of 40 CFR (60) OOOO for a tank affected facility. There are no other affected facilities that are installed. 5 AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Oil and Gas Industry: General Provisions [R307-501] Status: In Compliance. There are no general provisions that exceed the conditions already imposed by the Approval Order. See the evaluation in Section I above. Oil and Gas Industry: Pneumatic Controllers. [R307-502] Status: In Compliance. This source does not use continuous bleed natural gas-driven pneumatic controllers as described in 40 CFR 60.5365(d)(1). Oil and Gas Industry: Tank Truck Loading [R307-504] Status: In Compliance. The truck loading area is suitable for submerged loading and it is routine for truck drivers to load this way. This source is currently exempt from the installation of a vapor capture line by registration with an Approval Order. Oil and Gas Industry: Flares. [R307-503] Status: In Compliance. An enclosed combustor is installed and operating properly. The DAQ looked for design and installation parameters such as: The vessel vent line is sloped away from the inlet of the combustor, a two-phase scrubber is used to separate natural gas liquids or condensates, the combustor has a lit pilot with an auto-ignition device, and the inlet to the combustor is controlled by a pressure regulating device. PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-ADAQE-AN145450001-13-13, dated January 16, 2013: 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. HPV STATUS: Not Applicable. 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 remain as planned. The DAQ was joined by Javelin Energy personnel during the site inspection. NSR RECOMMENDATIONS: None ATTACHMENTS: None