HomeMy WebLinkAboutDAQ-2025-0030081
DAQC-CI155700001-25
Site ID 15570 (B1)
MEMORANDUM
TO: FILE – SM ENERGY COMPANY – Betts 2-26B1
THROUGH: Rik Ombach, Minor Source Oil and Gas Section Manager
FROM: Chris Jensen, Environmental Scientist
DATE: June 4, 2025
SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Duchesne County
INSPECTION DATE: April 16, 2025
SOURCE LOCATION: 40.2856788635254 -109.957801818848
Roosevelt, UT
DIRECTIONS:
SOURCE CONTACTS:
OPERATING STATUS: Operating
PROCESS DESCRIPTION: Oil and gas products are brought to the surface using a pumping
unit. These products go through a separator where the oil and
any water products are sent to storage tanks and the 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. Gas products are brought to the
surface. These products are sent to an off lease compressor
station nearby by underground piping.
APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN155700001-16, dated
November 8, 2016
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,
SOURCE EVALUATION:
Name of Permittee: Permitted Location:
SM Energy Company - Betts 2-26B1
1700 Lincoln Street, Suite 3200 Suite 390 40.2856788635254 -109.957801818848
Denver, CO 80203 Roosevelt, UT
SIC Code: 1311: (Crude Petroleum & Natural Gas)
# - $ . ) . )
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Section I: GENERAL PROVISIONS
I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the
UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to
those rules. [R307-101]
Status: In Compliance.
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
Status: In Compliance. This source did not exceed any of the limits set in the AO.
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions
covered by this AO must be reviewed and approved. [R307-401-1]
Status: In Compliance. The DAQ did not identify any modifications or unauthorized
equipment.
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless
otherwise specified in this AO or in other applicable state and federal rules, records shall be kept
for a minimum of two (2) years. [R307-401-8]
Status: In Compliance. The recordkeeping procedures are found to be orderly and
complete. All requested records were made available to the DAQ in a timely manner.
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall,
to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control
practice for minimizing emissions. Determination of whether acceptable operating and
maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection of the source. All maintenance performed
on equipment authorized by this AO shall be recorded. [R307-401-4]
Status: Out of Compliance. A PRV is found venting fugitive tank emission as the ECD is
not combusting and pilot is not lit. The PRV may have limited the "fuel" to allow the ECD to function properly. At any rate, the pilot should have been lit as it is required to have a
continuous flame. The poor operation or maintenance of these pieces of equipment has
resulted in excess emissions to the atmosphere.
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]
Status: In Compliance. No reported breakdowns.
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
Status: In Compliance. Emission totals for the criteria pollutants were reported to the 2023 inventory for this source.
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Section II: SPECIAL PROVISIONS
II.A The approved installations shall consist of the following equipment:
II.A.1 Betts 2-26B1 Production Tank Battery
II.A.2 Pump-Jack Engines Maximum Site-wide Rating: 130 hp combined Maximum Single Engine Rating: 65 hp Fuel: Natural Gas
II.A.3 Boilers & Heaters Includes: heater treaters, separators and tank heaters Maximum Total Capacity: 9.0 MMBtu/hr combined Fuel: Natural Gas
II.A.4 Oil Storage Tanks Maximum Total Capacity: 2,400 barrels combined
II.A.5 Produced Water Storage Tanks Maximum Total Capacity: 800 barrels combined
II.A.6 Enclosed Combustor
II.A.7 Pit Tank Maximum Total Capacity: 200 barrels combined
II.A.8 Pneumatic Controllers Low Bleed Devices Maximum Quantity: 25
II.A.9 Truck Loading Operations Submerged loading
II.A.10 Miscellaneous Storage Tanks Storage of motor oil, methanol, glycol, etc Maximum Total Capacity: 1,000 gallons combined
II.B Requirements and Limitations
II.B.1 Site-Wide Requirements. II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any stationary point or fugitive emission source on site to exceed 10 percent opacity. [R307-401-8] Status: In Compliance. No visible emissions were detected. II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3] Status: In Compliance. For the evaluation, the DAQ used EPA Method 9. II.B.1.b The owner/operator shall only use natural gas as fuel in the pump-jack engines, boilers and heaters on site. [R307-401-8] Status: Not Applicable.
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II.B.2 Tank Requirements. II.B.2.a The owner/operator shall not produce more than 120,000 barrels (1 barrel = 42 gallons) of crude oil per rolling 12-month period. [R307-401-8] Status: In Compliance. A search of DOGM records found 9,365 BBLs of crude were produced in the preceding 12-month period. II.B.2.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the twentieth day of each month using the most recent 12 months of production data reported to the Utah Division of Oil, Gas and Mining. Records of crude oil production shall be kept for all periods when the plant is in operation. Crude oil production shall be determined by process flow meters and/or sales records. [R307-401-8] Status: In Compliance. II.B.2.b At least once each month, the owner/operator shall inspect each closed vent system (including tank openings, thief hatches, and bypass devices) for defects that could result in air emissions according to 40 CFR 60.5416a(c). Records of inspections shall include the date of the inspection and the results of the inspection. [R307-401-8, 40 CFR 60 Subpart OOOOa] Status: In Compliance. The operator supplied inspection forms for review. These inspections were conducted monthly as required by 40 CFR (60) OOOOa. II.B.2.c The owner/operator shall keep the storage tank thief hatches closed with a weighted mechanism or equivalent, to ensure that the lid remains properly seated, except during tank unloading or other maintenance activities. [R307-401-8] Status: In Compliance. All hatches were found closed at the start of the evaluation. II.B.2.d The owner/operator shall inspect the thief hatches at least once every three months to ensure the thief hatches are closed, latched, and the associated gaskets, if any, are in good working condition. Records of thief hatch inspections shall include the date of the inspection and the status of the thief hatches. [R307-501] Status: In Compliance. The operator supplied inspection forms for review. These inspections were conducted monthly as required by 40 CFR (60) OOOOa in excess of this requirement. II.B.3 Pump-Jack Engine Requirements II.B.3.a Regardless of construction, reconstruction, or modification date, each stationary engine with a maximum engine power greater than 25 hp and less than 100 hp shall comply with 40 CFR 60.4233(d), 40 CFR 60.4233(h), 40 CFR 60.4243(b), 40 CFR 60.4243(e), 40 CFR 60.4243(f), and 40 CFR 60.4245. [40 CFR 60 Subpart JJJJ, R307-401-8] Status: Not Applicable. II.B.4 Leak Detection and Repair Requirements II.B.4.a The owner/operator shall conduct a leak detection inspection for each valve(s), flange(s) or other connection, pump(s), compressor(s), pressure relief device(s) or other vent(s), process drain(s), open-ended valve(s), pump seal(s), compressor seal(s), and access door seal(s) or other seal containing or contacting a process stream with hydrocarbons that is associated with each of the approved emission units listed in Section II: Special Provisions.
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Leak detection inspections shall be conducted according to the following schedule: A. No later than 180 days from the date of this AO. B. At least once every 12 months after the initial leak detection inspection. [R307-401-8] Status: In Compliance. The operator supplied LDAR inspection forms for review. These inspections were conducted quarterly in excess of this requirement. II.B.4.b Inspections shall be conducted in one of two ways; 1. An analyzer that meets U.S. EPA Method 21, 40 CFR Part 60, Appendix A 2. An optical gas imaging instrument as defined in 40 CFR 60.18(g)(4) The optical gas imaging instrument must meet requirements specified in 40 CFR 60.18(i)(3). Any emissions detected with an optical gas imaging instrument shall be considered a leak in need of repair unless the owner/operator evaluates the leak with an analyzer meeting U.S. EPA Method 21, 40 CFR Part 60 and the analyzer reading is less than 500 ppmv. A reading of 500 ppmv or greater shall be considered a leak in need of repair. Emissions detected from tank gauging, load-out operations, venting of pneumatics, properly operating pressure relief valves, or other maintenance activities shall not be considered leaks. [R307-401-8] Status: In Compliance. The operator uses a Flir GF 320 OGI camera. II.B.4.c The owner/operator is exempt from inspecting a valve, flange or other connection, pump or compressor, pressure relief device, process drain, open-ended valve, pump or compressor seal system degassing vent, accumulator vessel vent, agitator seal, or access door seal under any of the following circumstances: A. The contacting process stream only contains glycol, amine, methanol, or produced water. B. Monitoring could not occur without elevating the monitoring personnel more than six feet above a supported surface or without the assistance of a wheeled scissor-lift or hydraulic type scaffold. C. Monitoring could not occur without exposing monitoring personnel to an immediate danger as a consequence of completing monitoring. D. The item to be inspected is buried, insulated in a manner that prevents access to the components by a monitor probe, or obstructed by equipment or piping that prevents access to the components by a monitor probe. [R307-401-8] Status: In Compliance. Inspections under these conditions are covered in the Emissions monitoring plan. II.B.4.d If a leak is detected at any time, the owner/operator shall attempt to repair the leak no later than 5 calendar days after detection. Repair of the leak shall be completed no later than 15 calendar days after detection, unless parts are unavailable or unless repair is technically infeasible without a shutdown. The owner/operator shall inspect the repaired leak no later than 15 calendar days after the leak was repaired to verify that it is no longer leaking.
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If replacement parts are unavailable, the replacement parts must be ordered no later than 5 calendar days after detection, and the leak must be repaired no later than 15 calendar days after receipt of the replacement parts. If repair is technically infeasible without a shutdown, the leak must be repaired by the end of the next shutdown. If a shutdown is required to repair a leak, the shutdown must occur no later than 6 months after the detection of the leak unless the owner/operator demonstrates that emissions generated from the shutdown are greater than the fugitive emissions likely to result from delay of repair. [R307-401-8] Status: In Compliance. The supplied inspection forms showed that the latest surveys did not find any leaks. II.B.4.e Records of inspections and leak detection and repair shall include the following: A. The date of the inspection B. The name of the person conducting the inspection C. Any component not exempt under II.B.4.c that is not inspected and the reason it was not inspected D. The identification of any component that was determined to be leaking E. All records shall be maintained for optical gas imaging instrument as per 40 CFR 60.18(i)(4)(vi) F. The date of first attempt to repair the leaking component G. Any component with a delayed repair H. The reason for a delayed repair 1. For unavailable parts: i. The date of ordering a replacement component ii. The date the replacement component was received 2. For a shutdown: i. The reason the repair is technically infeasible ii. The date of the shutdown iii. Emission estimates of the shutdown and the repair if the delay is longer than 6 months I. Corrective action taken J. The date corrective action was completed K. The date the component was verified to no longer be leaking
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L. The records of each component exempt under II.B.4.c 1. Type of component 2. Description of qualifying exemption [R307-401-8] Status: In Compliance. II.B.5 Combustor Requirements II.B.5.a All exhaust gas/vapors from the produced water and oil storage tanks shall be routed to the operating combustor. [R307-401-8] Status: In Compliance. Tank emissions are routed to an enclosed combustor. II.B.5.b The combustor shall operate with a continuous pilot flame and an auto-igniter. [R307-503-4] Status: Out of Compliance. There was no visible flame from the pilot. II.B.5.c The combustor shall operate with no visible emissions. [R307-401-8] Status: In Compliance. No visible emissions were detected. II.B.5.c.1 Visual determination of smoke emissions from flares shall be conducted according to 40 CFR 60, Appendix A, Method 22. [R307-401-8] Status: In Compliance. The operator indicated on the monthly inspection records that they use the EPA method 22.
Section III: APPLICABLE FEDERAL REQUIREMENTS
In addition to the requirements of this AO, all applicable provisions of the following federal programs
have been found to apply to this installation. This AO in no way releases the owner or operator from any
liability for compliance with all other applicable federal, state, and local regulations including UAC
R307.
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
Status: Out of Compliance. This source has an Approval Order from the State of Utah with legal and
enforceable limits. This source is exempt from OOOOa for the collection of fugitive emissions
components. A monitoring, repair, and record keeping program is in place that would satisfy the
requirements of 40 CFR (60) OOOOa for the collection of fugitive emissions components, closed vent
system, and storage vessel facilities. The enclosed combustor was not operating correctly and the pilot
was not lit at the time of inspection. This condition would have the storage tank and vessel vent affected
facilities out of compliance. There are not other affected facilities installed.
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AREA SOURCE RULES EVALUATION:
The following Area Source Rules were evaluated during this inspection:
Oil and Gas Industry: General Provisions [R307-501]
Status: Out of Compliance. A PRV was found allowing fugitive emissions to the atmosphere. The
enclosed combustor is not operating properly calling into question if these components are being
properly maintained or checked.
Oil and Gas Industry: Pneumatic Controllers. [R307-502]
Status: In Compliance. This source does not use continuous bleed natural gas-driven pneumatic
controllers as described in 40 CFR 60.5365(d)(1).
Oil and Gas Industry: Tank Truck Loading [R307-504]
Status: In Compliance. The truck loading area is suitable for submerged loading and it is routine for
truck drivers to load this way. It is also plumbed for vapor recovery during truck loading.
Oil and Gas Industry: Flares. [R307-503]
Status: Not Applicable. This location does not have a flare for associated gas. The enclosed
combustor is for tank emissions.
PREVIOUS ENFORCEMENT
ACTIONS: None in the last 5 years.
COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN155700001-16,
dated November 8, 2016, the overall status is: Out of
Compliance. This source was found to be clean and well-kept
with no visible emissions. The source was inspected by AVO
and with an OGI camera and found the PRV to be leaking,
possibly stuck open. SM Energy personnel commented that that
particular model is unreliable and it is slated for replacement.
Parts are in stock now and installations have begun. He could not
say when this particular one is scheduled for replacement but,
will check and move it to the top of the order. No other fugitive
emissions were found from other components. The pilot was not
lit and the combustor was not operating likely from the loss of
pressure from the PRV. The operator's representatives were
pleasant and cooperative. Requested records were provided in a
timely manner and reviewed at the local field office. The DAQ
recommends that SM Energy answer to a Compliance Advisory.
During the records review portion (April 23, 2025), of the
evaluation, SM Energy personnel reported that the 50% PRV has
been replaced with a better model and the orifice on the ECD
pilot was replaced. The DAQ received a response to the
Compliance Advisory and has composed a No Further Action
letter.
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HPV STATUS: Not Applicable.
RECOMMENDATION FOR
NEXT INSPECTION: The DAQ has no recommendations for the next inspector other
than what are customary. The DAQ was joined by SM Energy
personnel during the site inspection.
NSR RECOMMENDATIONS: None
ATTACHMENTS: None