HomeMy WebLinkAboutDAQ-2025-0016101
DAQC-PBR151540001-25
Site ID 15154 (B1)
MEMORANDUM
TO: FILE – Ovintiv USA Inc. – Evans 14-25-3-3W
THROUGH: Rik Ombach, Minor Source Oil and Gas Section Manager
FROM: Fred Goodrich, Environmental Scientist
DATE: March 14, 2025
SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION
INSPECTION DATE: February 20, 2025
SOURCE LOCATION: Lat: -110.175323486328 Long: 40.1888046264648
Business Office:
Ovintiv USA Inc.
370 17th Street Suite 1700
Denver, CO 80202
SOURCE TYPE: Tank Battery
Duchesne
API: 4301351177
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:
24,000 Estimated Oil BBL.
DOGM current 12 month rolling production is: 20,123 BBL's..
Utah Statute R307-506 requires a source with throughput
greater than 8,000 BBLs to have controls.
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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. VOC emissions found reasonably minimized at the time of inspection. 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. Associated Gas 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. In place and operating per manufactures design. 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. Truck loading done by bottom or submerged filling at the time of 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. 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. VOCs from storage vessels found properly routed to combustor. Combustors and VOC Control Devices Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-4(2)] In Compliance. Vessel lines are correctly installed according to design.
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Combustor 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. All necessary components appear in place and operating per manufactures design. The VOC control device(s) required by R307-506 or R307-507 has a control efficiency of 95% or greater, operates with no visible emissions and has a continuously burning pilot flame and an operational auto-igniter according to R307-503. [R307-508-3(1)] In Compliance. SFI brand combustor designed and engineered for 95% burn efficiency. No excessive visible opacity observed during evaluation. 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. Reviewed at local field office. Emission Inventory An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. The operator submitted for the 2023 emissions inventory. The source has a source specific emissions monitoring plan. [R307-509-4(1)(a)] In Compliance. Reviewed at local field office. Monitoring surveys are conducted to observe each fugitive emissions component for fugitive emissions. [R307-509-4(1)(c)] 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. Operator uses a Flir 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. Operator meets the standards set forth. Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] In Compliance. Records reviewed with operator.
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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. 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. Source appears to be in order at the time of evaluation. 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 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. Reviewed at local field office.
PREVIOUS ENFORCEMENT
ACTIONS: None in the past 5 years.
COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to the site, the overall status is: In Compliance.
The DAQ was joined by Ovintiv personnel during the site
inspection. OGI camera was used during evaluation, no fugitive
emissions were detected. Source was clean and well kept. DAQ
recommends frequency of inspections remain current as
scheduled
RECOMMENDATION FOR
NEXT INSPECTION: Recommend to keep inspection frequency the same.
RECOMMENDATIONS FOR NSR: None.
ATTACHMENTS: None.