The URL can be used to link to this page

Home My WebLink AboutDAQ-2025-0020061 DAQC-PBR151280001-25 Site ID 15128 (B1) MEMORANDUM TO: FILE – FOURPOINT RESOURCES, LLC – Lucy 2-15-22-3-2WH THROUGH: Rik Ombach, Minor Source Oil and Gas Section Manager FROM: Fred Goodrich, Environmental Scientist DATE: April 4, 2025 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: February 27, 2025 SOURCE LOCATION: Lat: -110.10009765625 Long: 40.2305145263672 Business Office: FourPoint Resources, LLC 100 Saint Paul Street, Suite 400 Denver, CO 80206 SOURCE TYPE: Tank Battery Duchesne API: 4301352316, 4301352317 SOURCE CONTACTS: Brad Rowser, Field Contact Phone: 435-646-4870, Email: brad.rowser@ovintiv.com Jeanette Liang, Corporate Environmental Contact Phone: 303-248-6822, Email: jliang@fourpointenergy.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: 40 CFR 60 Subpart OOOO. SOURCE EVALUATION: Site Type: PBR-Controlled Controlled by flare, Site has Line Power. The source registered: 100,000 Estimated Oil BBL. , - 2 DOGM current 12 month rolling production is: 24,666 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 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 appeared to maintain VOC's in a responsible manner. 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. All necessary components appear 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. 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. 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. OGI camera was used during evaluation. No emissions were detected. 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. Source is controlled by flare. 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 components properly in place and operating to manufactures specifications. 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. 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 properly in place and operating to manufactures specifications. 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. Control equipment designed to meet any variables associated with source fluctuations. 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 found operating at proper destruction level with no visible emissions. 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. 4 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. 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. Records observed at local field office and appear to be orderly and complete. 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. 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 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. Applicable Federal Regulations NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution [40 CFR 60 Subpart OOOO] In Compliance. Source appears to meet these standards set forth. 5 PREVIOUS ENFORCEMENT ACTIONS: None in the past 5 years. COMPLIANCE STATUS & RECOMMENDATIONS: In Compliance. DAQ was joined by FourPoint Resources 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 to decrease as scheduled. RECOMMENDATION FOR NEXT INSPECTION: Recommends frequency of inspections to decrease as scheduled. RECOMMENDATIONS FOR NSR: None. ATTACHMENTS: None.