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Home My WebLink AboutDAQ-2024-0074321 DAQC-PBR083170002-24 Site ID 8317 (B1) MEMORANDUM TO: FILE – QUINEX ENERGY CORPORATION – Kathy Boydstun 2-13A1 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Kyle Greenberg, Environmental Scientist DATE: April 3, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: February 21, 2024 SOURCE LOCATION: Kathy Boydstun 2-13A1 Lat:40.401415 Long: -109.940721 Business Office: 465 South 200 West #300 Bountiful, UT 84010 SOURCE TYPE: Tank Battery Uintah County API: 4304753709 SOURCE CONTACTS: Brad Wells, Corporate Environmental Contact Email: brad@quinexenergy.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, and 40 CFR 60 Subpart OOOO. SOURCE EVALUATION: Site Type: PBR- Controlled Controlled by flare Site powered by Engine The source registered: 11463 Estimated Oil BBL. 2 DOGM current 12 month rolling production is: 8,473 bbls. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: 2 – 500 bbl crude oil tanks; 1 – 500 bbl produced water tank; 1 – 500 bbl emergency tank; 1 – Separator; 1 – 3 MMBtu/hr Boiler (heat trace); 1 – Combustor; 1 – Electric engine pumpjack General Provisions VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] In Compliance. Air pollution control equipment is designed and installed appropriately, maintained and operated to control emissions. [R307-501-4(2)] In Compliance. Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-2] In Compliance. 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. [R307-501-2] In Compliance. Pneumatic Controllers Continuous bleed natural gas-driven pneumatic controllers are in compliance with 40 CFR 60.5390 or 60.5390a as applicable. Exemptions to tagging and record keeping requirements apply to controllers existing before 12/1/2015. [R307-502-4] In Compliance. Quinex confirmed that all pneumatic controllers on site are low-bleed and have a bleed rate less than or equal to 6 standard cubic feet per hour. Flares Any flare has an operational auto-igniter. [R307-503-4] In Compliance. Tank Truck Loading Truck loading is done by bottom filling or submerged fill pipe [R307-504(1)] In Compliance. 3 A vapor capture line is used during truck loading if subject to storage vessel emissions controls of R307-506-4(2). Effective 7/1/2019 for sources existing before 1/1/2018, and upon construction for new sources. [R307-504-4(2)] In Compliance. Oil and Gas Industry Registration Requirement The source is registered with the DAQ. [R307-505-3(3)] In Compliance. 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. Storage Vessels Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. 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. DOGM records show that the well produced 8,473 bbls of crude oil in the reporting periods from March 2023 through February 2024. The storage vessels are controlled with a combustor. Emissions from emergency storage vessels are controlled according to R307-506-4(2), or are only used in emergencies, are emptied within 15 days of receiving fluids and are equipped with a liquid level gauge. [R307-506-4(4)] In Compliance. Upon modification, the well site was re-evaluated against the thresholds of R307-506-4(2). [R307-506-4(6)] Not applicable. Well has not been modified since the previous inspection conducted on October 27, 2022. 4 Records for each of the following are kept for three years: Storage vessel vent system inspections (openings, thief hatches, pressure relief devices, bypasses, etc.), if required 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 per R307-506-4(2). [R307-506-5] In Compliance. Records were reviewed and made available when asked. See attached records from March 2023 through April 2024. The emergency storage vessel is controlled by the combustor on-site and Monthly crude oil throughput is not required for Emission calculations due to the throughput being greater than 8,000 bbls. VOC Control Devices 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 an operational auto-igniter according to R307-503. [R307-508-3(1)] In Compliance. No visible emissions were observed from the combustor during the time of inspection. Combustor was lit and operating during the time of inspection. Monthly AVO inspections are conducted on VOC control devices and associated equipment, and corrective actions are taken within 15 days. [R307-508-3(3)] In Compliance. See attached records from March 2023 through February 2024. The following records are kept: VOC control device efficiency, for life of the equipment Manufacturer operating and maintenance instructions for VOC control devices, for life of the equipment AVO inspections of the VOC control device(s), associated equipment and any repairs, for 3 years. [R307-508-4] In Compliance. AVO inspections are conducted on the VOC control device, see attached records. Leak Detection and Repair The source has an emissions monitoring plan. [R307-509-4(1)(a)] In Compliance. The monitoring plan addresses difficult-to-monitor and unsafe-to-monitor components. [R307-509-4(1)(b)] In Compliance. 5 If emissions control is required, monitoring surveys are conducted to observe each fugitive emissions component for fugitive emissions. [R307-509-4(1)(c)] In Compliance. Initial monitoring surveys were within 60 days after startup for new sources. Subsequent surveys are semi-annual 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. Monitoring surveys are done with OGI equipment or by Method 21. [R307-509-4(1)(e)] In Compliance. Fugitive leaks are 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. Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] In Compliance. 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. LDAR is conducted on a semi-annual basis. LDAR inspections were last conducted on April 2023 and October 2023, see attached records. Natural Gas Engines Engines subject to R307-510 (does not have an AO, began operations, installed or modified after January 1, 2016) meet the following limits: Maximum Engine hp Emission Standards in (g/hp-hr) NOx CO VOC HC+NOx >25 hp and < 100 hp - 4.85 - 2.83 >100 hp 1.0 2.0 0.7 - [R307-510-4(1)] Not Applicable. All engines on-site were electric during the time of inspection. Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)] Not Applicable. All engines on-site were electric during the time of inspection. 6 Affected engine exhaust vents are vertical and unrestricted. Stacks are 8' or greater if the site horsepower rating is 151 to 305 Stacks are 10' or greater if the site horse power rating is 306 or greater. [R307-510-4(3)] Not Applicable. All engines on-site were electric during the time of inspection. Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] Not Applicable. All engines on-site were electric during 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 from the well is directed into a sales pipeline. The following records are kept: The time and date of event Volume of emissions Any corrective action taken for 3 years. [R307-511-5(1)(a)(b)] In Compliance. See attached records. Visible Emissions Visible emissions, except for unavoidable irregularities that do not exceed three minutes, are within the following opacity limits: Installations constructed on or before 4/25/1971 40% Installations constructed after 4/25/1971 20% Gasoline engines 0% Diesel engines manufactured after 1/1/1973 20% Diesel engines manufactured before 1/1/1973 40% Note: Required VOC control devices shall have no visible emissions per R307-508-3. [R307-201-3] In Compliance. No visible emissions were observed during the time of inspection. 7 Emission Inventory: An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution [40 CFR 60 Subpart OOOO] In Compliance. The site is in compliance with all legally and practically enforceable limits of the Utah DAQ. PREVIOUS ENFORCEMENT ACTIONS: CA: DAQC-1645-20 NFA: DAQC-096-21 CA: DAQC-1489-22 ESA: DAQC-075-23 Signed ESA: DAQC-298-23 COMPLIANCE STATUS & RECOMMENDATIONS: In regards to: Kathy Boydstun 2-13A1: In Compliance – During the time of inspection the installation and air pollution control equipment appeared to be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. It is recommended to inspect the site on regularly scheduled interval. RECOMMENDATION FOR NEXT INSPECTION: Memo: Check production throughput of crude oil; the current throughput is in the low 8,000 bbls per rolling 12-months. ATTACHMENTS: AVO, thief hatch, and LDAR inspection records.