HomeMy WebLinkAboutDAQ-2025-0028181
DAQC-PBR047260001-25
Site ID 4726 (B1)
MEMORANDUM
TO: FILE – JAVELIN ENERGY LLC – REARY 2-17A3
THROUGH: Rik Ombach, Minor Source Oil and Gas Section Manager
FROM: Fred Goodrich, Environmental Scientist
DATE: June 3, 2025
SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION
INSPECTION DATE: May 16, 2025
SOURCE LOCATION: Lat: 40.3950004577637, Long: -110.252967834473
Duchesne County
Business Office:
Javelin Energy Management Partners, LLC
6333 North State Highway 161, Suite 500
Irving, TX 75039
SOURCE TYPE: Tank Battery
API: 4301331318
SOURCE CONTACTS: Brian Shpakoff, Corporate Environmental Contact
Phone: 682-209-2074,
Email: Brian.Shpakoff@crescentenergyco.com
Jennifer McQueen, Corporate Environmental Contact
Phone: 720-705-8042, Email: jmcqueen@slrconsulting.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:
8,796 Estimated Oil BBL.
, -
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DOGM current 12 month rolling production is:
26,480 BBL's.
Utah Statute R307-506 requires a source with throughput
greater than 8,000 BBLs to have controls.
REGISTERED EQUIPMENT Engine - 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 equipment is designed and properly functioning as intended to control emissions. 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. 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. 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. 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 from components. 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. Enclosed combustor in place and operating.
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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. 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. Operating efficiently with no visible opacity observed. Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-4(2)] In Compliance. Lines appear sloped per manufactures design and request. 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. Appears that operator has installed correct equipment per manufactures suggested 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. Engineered to meet existing operating conditions. 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 to a sales pipeline 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. 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.
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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. Reviewed at local field office. VOC Control Devices 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. 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. 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. 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. Surveys are performed on a monthly basis. These records were reviewed at the local 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. The following records are kept: The emissions monitoring plan, for life of the site LDAR inspections, repairs and resurveys, for 3 years [R307-509-5] 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 In Compliance.
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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. DAQ recommends frequency of inspections
remain current as scheduled.
RECOMMENDATION FOR
NEXT INSPECTION: The DAQ has no recommendations for the next inspector other
than what are customary.
UNDER EPA DECREE: Yes.
ATTACHMENTS: None.