Loading...
HomeMy WebLinkAboutDAQ-2025-0016181 DAQC-PBR158250001-25 Site ID 15825 (B1) MEMORANDUM TO: FILE – OVINTIV USA INC. – Beal UT 13-34-3-3 THROUGH: Rik Ombach, Minor Source Oil and Gas Section Manager FROM: Fred Goodrich, Environmental Scientist DATE: March 17, 2025 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: January 23, 2025 SOURCE LOCATION: Lat: -110.217643737793 Long: 40.1731338500976 Business Office: Ovintiv USA Inc. 370 17th Street Suite 1700 Denver, CO 80202 SOURCE TYPE: Tank Battery Duchesne API: 4301353578, 4301353579 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: 100,000 Estimated Oil BBL. DOGM current 12 month rolling production is: 25,061 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. Operator appears to have met practicable operating conditions with equipment design. 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-ignitor found installed and in working order at the time of inspection. 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. All necessary equipment in place and operable. 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. Vapor capture line installed and appears operable for use 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. Vessel Vent Components: (valves, unions, pressure relief devices, etc.) are leak-free, in good repair, and working as intended. (Tank covers are leak free and form a continuous seal.). [R307-501-4] In Compliance. Components appear in place and operating as intended. OGI camera found no issues. 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 at the time of inspection. 3 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. All necessary equipment in place and operable. Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-4(2)] In Compliance. Vessel vent lines appear to meet manufactures design. 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. Operator appears to meet manufactures requested equipment design. Air pollution control equipment is designed and sized to achieve the destructive efficiencies in rules and to handle fluctuations in emissions. [R307-501-4(2)] In Compliance. Air assisted flare sized 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. Control device operating at greater than 95 percent efficiency with no visible emissions at the time of inspection. 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 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. Records observed at local field office and appear to be orderly and complete. Monitoring surveys are done with OGI equipment or by Method 21. [R307-509-4(1)(e)] In Compliance. Surveys are conducted using OGI equipment. 4 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 meet this requirement. 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. 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. 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. NIC-NAR issued January 22, 2024, for emissions from produced water tank PRV. Operator corrected in a timely manner. Re-evaluation of source on January 23, 2025, found no issues. RECOMMENDATION FOR NEXT INSPECTION: Source was found in compliance. DAQ recommends frequency of inspections to a suggested two-year rotation schedule. RECOMMENDATIONS FOR NSR: None. ATTACHMENTS: None.