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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. , - 2 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. 3 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. 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 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.