Loading...
HomeMy WebLinkAboutDAQ-2025-0009671 DAQC-PBR151460001-25 Site ID 15146 (B1) MEMORANDUM TO: FILE – OVINTIV USA INC. – Alzada 11-21-3-2W THROUGH: Rik Ombach, Minor Source Oil and Gas Section Manager FROM: Fred Goodrich, Environmental Scientist DATE: February 7, 2025 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: November 14, 2024 SOURCE LOCATION: Lat: 40.20515 Long: -110.11754 Business Office: Ovintiv USA Inc. 370 17th Street Suite 1700 Denver, CO 80202 SOURCE TYPE: Tank Battery Duchesne API: 4301351068 SOURCE CONTACTS: Ryan Zillner, Corporate Environmental Contact Phone: 720-876-3144, Email: ryan.zillner@ovintv.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: SOURCE EVALUATION: Site Type: PBR-Controlled Controlled by flare, Site has Line Power. The source registered: 40,000 Estimated Oil BBL. DOGM current 12 month rolling production is: 32,000 BBL's.. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. , - 2 REGISTERED EQUIPMENT: Pneumatic, Tank General Provisions 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 excessive opacity limits were observed 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. 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 manufactures engineered 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 and latched down at the start of the evaluation. 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. Appears that operator has installed correct equipment per manufactures suggested design. 3 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. Combuster inlet lines are equipped with a fire arrestor, pressure gauge, inlet pressure regulating valve and other components according to the engineering design, the manufacturer's specifications or good practices for safety and emissions control. [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. 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: The source has a source specific emissions monitoring plan. [R307-509-4(1)(a)] In Compliance. Reviewed at local field office. 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. Reviewed at local field office. Monitoring surveys are done with OGI equipment or by Method 21. [R307-509-4(1)(e)] In Compliance. The operator uses a Flir GF 320 OGI camera. 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. Reviewed at local field office. Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] In Compliance. Reviewed at local field office. 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 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. 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. The recordkeeping procedures of the operator are found to be orderly and complete. These records were reviewed at the local office. Applicable Federal Regulations: NSPS (Part 60) OOOOa: Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015 [40 CFR 60 Subpart OOOOa] In Compliance. PREVIOUS ENFORCEMENT ACTIONS: None in the past 5 years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to the site, the overall status is: 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. RECOMMENDATION FOR NEXT INSPECTION: The last DAQ inspector found 1 inch dry gas line leaking in December of 2023. Operator promptly addressed found issue. Source was re-inspected in November of 2024 by two DAQ inspectors. Upon the latest visit, source was found to be in compliance. DAQ suggests next inspection to occur within a minimum of two years. RECOMMENDATIONS FOR NSR: None. ATTACHMENTS: None.