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HomeMy WebLinkAboutDAQ-2024-0121451 DAQC-PBR151850001-24 Site ID 15185 (B1) MEMORANDUM TO: FILE – OVINTIV USA, INC. – Yergensen 7-7-3-1W THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Fred Goodrich, Environmental Scientist DATE: December 16, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: November 16, 2024 SOURCE LOCATION: Lat:40.240219, Long: -110.0363 Duchesne County Business Office: Ovintiv USA, Inc. 370 17th Street, Suite 1700 Denver, CO 80202 SOURCE TYPE: Tank Battery API: 4301350985 SOURCE CONTACTS: Ryan Zillner, Corporate Environmental Contact Phone: 720-876-3144, Email: ryan.zillner@ovintiv.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. Federal Subpart: 40 CFR 60 Subpart JJJJ, 40 CFR 60 Subpart OOOO. , - 2 SOURCE EVALUATION: Site Type: PBR – Uncontrolled No Flare Controls, Site has Line Power. The source registered: 7999 Estimated Oil BBL. DOGM current 12 month rolling production is: 4,300 BBL's. 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 - Arrow Model - L795 Mfg Year - 1990 Horse Power - 65 Combustion - Field Gas, 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 detected during evaluation. VOC emissions are, at all times, minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] In Compliance. All natural gas-driven pneumatic controllers are in compliance with 40CFR 60.5390 or 60.5390a as applicable. Tagging and record keeping requirements are not required. [R307-502-4] In Compliance. This source does not use continuous bleed controllers. Pneumatic Controllers Truck loading is done by bottom filling or submerged fill pipe [R307-504(1)] In Compliance. The truck loading valves were built and designed for submerged loading. Storage Vessels Thief hatches are kept closed and latched. [R307-506-4(1)] Out of Compliance. Thief hatch on tank 2 was found leaking with OGI Camera. Operator repaired after evaluation. 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. 3 Air pollution control equipment is installed appropriately, maintained and operated, pursuant to the manufacturers specifications, to control emissions. [R307-501-4(2)] In Compliance. Uncontrolled source. No combustor on facility. 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. Pre-2016 source. Meets this requirement. 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. 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. Engines subject to R307-510 shall be certified or have an initial performance test per CFR 60.4244. [R307-510-4(2)] In Compliance. Pre-2016 source. Operator appears to meet JJJJ. Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. Operator meets this requirement. 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. Initial startup on source was 2014. Records reviewed at local field office shows Ovintiv's engine maintenance plan appeared in order. 4 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. Records reviewed at local field office and appeared to meet this requirement. NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines [40 CFR 60 Subpart JJJJ] In Compliance. Operator appears to meet this requirement. NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution [40 CFR 60 Subpart OOOO] In Compliance. Source startup 2014 and appears to meet this standard. PREVIOUS ENFORCEMENT ACTIONS: None in the past 5 years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to the site, the overall status is: Out of Compliance. Tank number two had thief hatch leaking. Repaired same day. Uncontrolled source NIC NAR applied. RECOMMENDATION FOR NEXT INSPECTION: Increase inspections. RECOMMENDATIONS FOR NSR: None. ATTACHMENTS: None.