HomeMy WebLinkAboutDAQ-2025-0005851
DAQC-PBR157370001-25
Site ID 15737 (B1)
MEMORANDUM
TO: FILE – OVINTIV USA, INC. – Elmer 1-7-3-1WH
THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager
FROM: Fred Goodrich, Environmental Scientist
DATE: January 24, 2025
SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION
INSPECTION DATE: November 14, 2024
SOURCE LOCATION: Lat:40.242253, Long: -110.03072
Duchesne County
Business Office:
Ovintiv USA, Inc.
370 17th Street, Suite 1700
Denver, CO 80202
SOURCE TYPE: Tank Battery
API: 4301351400, 4301353440
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.
SOURCE EVALUATION: Site Type: PBR – Controlled
Controlled by flare, Site has Line Power. The source registered:
100000 Estimated Oil BBL.
, -
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DOGM current 12 month rolling production is: 14,689 BBL's.
Utah Statute R307-506 requires a source with throughput
greater than 8,000 BBLs to have controls.
REGISTERED EQUIPMENT: Pneumatic, Tank
General Provisions
VOC emissions are, at all times, 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.
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 as described in 40 CFR
60.5365(d)(1).
Flares
Any flare has an operational auto-igniter and a continuously burning pilot flame. [R307-503-4]
In Compliance. Auto Igniter in place and operating as designed.
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 lines appears to be manufactured and designed per manufacturer
requirements.
Tank Truck Loading
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.
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. In place and appears operational during inspection.
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.
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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. Control device found operating at proper destruction level with no visible
emissions.
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)]
In Compliance. Properly installed and appears to be functional to design.
Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber).
[R307-501-4(2)]
In Compliance. Properly installed and appears to be functional to design.
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.
Monthly inspections are conducted according to 40 CFR 60.5416a(c) on the closed vent system,
openings, thief hatches and bypass devices if emissions control is required, and defects are repaired
within 15 days. [R307-506-4(5)]
In Compliance. Records observed at local field office and appear to be orderly and complete.
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.
Leak Detection and Repair:
Oil and Gas Industry Registration Requirement
The source is registered with the DAQ. [R307-505-3(3)] In Compliance. Source appears to be properly registered at the time of inspection.
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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 observed at local field office and appear to be orderly and complete.
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. Records observed at local field office and appear to be orderly and complete.
PREVIOUS ENFORCEMENT
ACTIONS: None in the past 5 years.
COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to the site, the overall status is: In Compliance.
Source was re-evaluated from an earlier 2024 Inspection that
found two small leaks. Upon the most recent and current
evaluation, OGI camera was used during inspection, no fugitive
emissions were detected. Source was found clean and well kept.
DAQ recommends frequency of inspections be moved back to an
intermittent schedule.
RECOMMENDATION FOR
NEXT INSPECTION: The DAQ has no recommendations for the next inspector other
than what are customary.
RECOMMENDATIONS FOR NSR: None.
ATTACHMENTS: None.