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Home My WebLink AboutDAQ-2024-0071071 DAQC-PBR024580001-23 Site ID 2458 (B1) MEMORANDUM TO: FILE – OVINTIV USA, INC. – Pekepovits UT 1-14-4-3 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Manager FROM: Stephen Foulger, Environmental Scientist DATE: November 16, 2023 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: November 2, 2023 SOURCE LOCATION: Pekepovits UT 1-14-4-3 Lat: 40.140899 Long: -110.181318 Business Office: 370 17th Street, Suite 1700 Denver, CO 80202 SOURCE TYPE: Tank Battery Duchesne County API: 4301353599, 4301353600 SOURCE CONTACTS: Brandon Lithgoe, Local Contact Phone: 281-847-6093, Email: brandon.lithgoe@ovintiv.com Ryan Zillner, Local 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, and 40 CFR 60 Subpart OOOO. 2 SOURCE EVALUATION: Site Type: PBR-Controlled Controlled by flare Site has Line Power The source registered: 50,000 Estimated Oil BBL. DOGM current 12 month rolling production is: 34,857 Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Pneumatic, Tank 3 General Provisions 4 VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] In Compliance. 5 Air pollution control equipment is designed and installed appropriately, maintained and operated to control emissions. [R307-501-4(2)] In Compliance. 6 Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-2] In Compliance. 7 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. 8 10 Flares 11 Any flare has an operational auto-igniter. [R307-503-4] In Compliance. Operational auto ignitor found installed and working at the time of inspection. 12 Tank Truck Loading 13 Truck loading is done by bottom filling or submerged fill pipe [R307-504(1)] In Compliance. Truck loading is set up for bottom filling or submerged filling. 14 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. Vapor capture line is available for use during truck loading. 3 15 Oil and Gas Industry Registration Requirement 16 The source is registered with the DAQ. [R307-505-3(3)] In Compliance. This source was found properly registered with the DAQ at the time of inspection. 17 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. This source was found properly registered with the DAQ at the time of inspection. 18 Storage Vessels 19 Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. Thief hatches were found closed and latched at the time of inspection. 20 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. VOC's were found properly controlled at the time of inspection. 23 Upon modification, the well site was re-evaluated against the thresholds of R307-506-4(2). [R307-506-4(6)] In Compliance. 24 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. These records were found to be compliant at the time of inspection. 25 VOC Control Devices 26 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 at the time of inspection 27 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. These records were found to be compliant at the time of inspection. 4 28 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. These records were found to be compliant at the time of inspection. 29 Leak Detection and Repair 30 The source has an emissions monitoring plan. [R307-509-4(1)(a)] In Compliance. These records were found to be compliant at the time of inspection. 31 The monitoring plan addresses difficult-to-monitor and unsafe-to-monitor components. [R307-509-4(1)(b)] In Compliance. These records were found to be compliant at the time of inspection. 32 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. These records were found to be compliant at the time of inspection. 33 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. These records were found to be compliant at the time of inspection. 34 Monitoring surveys are done with OGI equipment or by Method 21. [R307-509-4(1)(e)] In Compliance. These records were found to be compliant at the time of inspection. 35 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. These records were found to be compliant at the time of inspection. 36 Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] In Compliance. These records were found to be compliant at the time of inspection. 37 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. These records were found to be compliant at the time of inspection. 38 5 43 Associated Gas Flaring 44 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. 45 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. 46 Visible Emissions 47 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 at the time of inspections. 48 55 Emission Inventory: 56 An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. Emissions inventory was found properly reported at the time of inspection. 60 NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution [40 CFR 60 Subpart OOOO] In Compliance. PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to: Pekepovits UT 1-14-4-3: In Compliance - This source was found to be compliant at the time of inspection. Source 101805: Ouray 4-13-4-3 is currently being drilled and shares this source's location and should be completed within the next year. The recommendation to keep inspection frequency the same is put forth for consideration. 6 RECOMMENDATION FOR NEXT INSPECTION: This source was found to be compliant at the time of inspection. Source 101805: Ouray 4-13-4-3 is currently being drilled and shares this source's location and should be completed within the next year. The recommendation to keep inspection frequency the same is put forth for consideration. ATTACHMENTS: