Document 2R57nOJ5Q9xrORrG3rNKnL8R
DATE: SUBJECT: FROM: THRU: TO:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS
77 WEST JACKSON BOULEVARD CIDCAGO, ILLINOIS 60604
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CLEAN AIR ACT INSPECTION REPORT Utica Resource Operating, LLC- Den:veiler Well Pad, Salesville, Ohio
Natalie Topinka, Environmental Scientist AECAB (IL/IN)
Nathan Frank, Section Chief AECAB (IL/IN)
File
BASIC INFORMATION
Facility Name: Utica Resource Operating, LLC - Denveiler Well Pad
Facility Location: 39.988577, -81.386899, Salesville, Ohio
Date of Inspection: April 18, 2019
EPA Inspectors: I. Natalie Topinka, Environmental Scientist 2. Victoria Nelson, Environmental Engineer 3. Constantinos Loukeris, Environmental Engineer
Other Attendees: l . Maureen Kertes, EHS Professional, URO 2. Shannon Thompson, KC Harvey 3. Kevin Rothenbuhler, VP of Operations, URO
Contact Email Address: rnkertes@uticaresource.com
Purpose of Inspection: To assess compliance with NSPS Subpart 0000 and the facility's PTIO
Facility Type: oil and natural gas well pad
Regulations Central to Inspection: NSPS Subpart 0000
Arrival Time: 10:07 am Departure Time: 10:45 am
Inspection Type: LJ unan11orn1ceu 111specuon IZl Announced Inspection
OPENING CONFERENCE
IZl Credentials Presented IZl CBI warning to facility provided
The following information was obtained verbally from Ms. Kertes unless otherwise noted.
Company Ownership: This well pad, along with 10 others in Ohio, was constructed and formerly owned and operated by PDC Energy. Utica Resource Operating, LLC acquired the facilities in early 2018.
Process Description: At the well pad, an oil/gas/water emulsion is extracted from the formation through two wells. The emulsion from each well goes to a separator, from which the gas is sent to the sales line and the oil and water are piped to separate 400-barrel, atmospheric pressure, fixed-roof tanks on-site. The vapors from the tank headspaces are piped together and to a combustor for destruction. Each tank has a "thief' hatch on top for gaining access to the liquid when necessary. The thief hatches are set to relieve pressure should the pressure due to flashing, working, or breathing emissions from the liquids contained within the tanks get too high for the piping of the vapor capture system and combustor to accommodate.
Staff Interview: Mr. Rothenbuhler stated that URO had to replace the temperature controllers frequently due to leaks.
TOUR INFORMATION
EPA toured the facility: Yes
Data Collected and Observations: The Detweiler pad has eight tanks and three vapor recovery towers (VRT). It was unclear if the VRTs were operating or otherwise in service. We climbed the tank battery and observed the thief hatches and pressure relief devices. We noted a hydrocarbon odor on the catwalk and observed emissions from thief hatches, which increased in intensity and volume during dump events to the tanks. We observed a sticky paraffin build-up as well as liquid condensate droplets around several of the thief hatches. We recorded numerous FLIR videos of emissions from thief hatches and confirmed the presence of volatile organic compounds (VOC) in the emissions plume using a Photo Ionization Detector (PID). We observed emissions via the FLIR camera from
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temperature controllers and equipment related to the two separators. The combustor was operating at the time of the inspection.
Photos and/or Videos: were taken during the inspection.
Field Measnrements: were not taken during this inspection.
CLOSING CONFERENCE
Compliance Assistance: We shared what we observed with the FLIR camera with URO representatives.
Concerns: We had concerns about design and operation of the vapor capture and control systems at the facilities, which we discussed with URO representatives. We also discussed the concern that because these facilities were acquired from another company and much of the operations are currently contracted out, there appears to be a lack of historical infonnation and knowledge about how the facilities were constructed and are currently operated.
SIGNATURES
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Facility Name: Utica Resource Operating, LLC - Detweiier Well Pad Facility Location: 39.988577, -81.386899, Salesville, Ohio Date of Inspection: April 18, 2019
APPENDICES AND ATTACHMENTS
I. Digital image/video log 2. Digital images and videos on CD
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Facility Name: Utica Resource Operating, LLC -- Detweiler Well Pad Facility Location: 39.988577, -81.386899, Salesville, Ohio Date of Inspection: April 18, 2019
APPENDIX A: DIGITAL IMAGE LOG
1. Inspector Name: Natalie Topinka
3. Company/Facility Name:
Utica Resource Operating, LLC -
Detweiler ,vell Pad
5. Number of Images: 22
2. Date(s) of Inspection:
April 18, 2019
4. Street Address, City, State:
39.988577, -81.386899, Salesville, Ohio
6. Archival Record Location:
CD-R labeled "Utica Resource Operating, LLC Detweiler well pad - Inspection photos 4/18/19"
Image Number
1
File Name P4180019.JPG
2
'
P4180020.JPG
Date and time 4/18/2019 10:15 EDT 4/18/2019 10:15 EDT
3
P4180021.JPG
4
P4180022.JPG
4/18/2019 10:19 EDT 4/18/2019 10:23 EDT
5
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6
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7
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8
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9
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4/18/2019 4/18/2019 4/18/2019 4/18/2019 4/18/2019
Appendices Page 1 of 2
Latitude and Longitude 40.043056, -81.382778
40.043056, -81.382778
39.989167, -81.386667 39.989398, -81.386673
Description of Image
Thief hatch with condensate droplets & staining
Thief hatch with condensate droplets,
paraffin buildup, & staining Thief hatch with
condensate droplets,
paraffin buildup, & staining Thief hatch with
condensate droplets
Emissions from thief hatches viewed from ground level Emissions from
thlef hatch
Emissions from thief hatch
Emissions from thief hatch
Emissions from thief hatch
Facility Name: Utica Resource Operating, LLC -Detweiler Well Pad Facility Location: 39.988577, -81.386899, Salesville, Ohio Date of Inspection: April 18, 2019
10
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Appendices Page 2 of2
Emissions from thief hatch
Emissions from thief hatch
Emissions from
cL._ r L, _i \.iiJ~j 10!~1,..jj
Emissions from thief hatch
Emissions from thief hatch
Emissions from LP separator #1 enclosure vent Emissions from
temperature controller inside LP separator #1
enclosure Emissions from
other controllers inside LP separator #1 enclosure
Combustor stack
Emissions from LP separator #2 enclosure vent Emissions from
piping at LP separator #2
enclosure Intermittent emissions from 4/18/2019LP separator #2 enclosure vent Emissions from leak point in LP separator #2
enclosure