Document 2zJn8mabqEqDoYObBNwN0dEr

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL P.1-H}TECT!ON AGENCY REGION 5 77 \VES'r JACKSON BOULEVARD CHICAGO, ILUNOlS 60604 JUN O7 2019 CLEAN AIR ACT INSPECTION REPORT Ascent Resources -- Ace Well Pad, Cadiz, Ohio Constantinos Loukcris, Environmental Engineer AECAB (1\,n/WI) Sarah Marshall, Section Chief AECAB (MI/WI) File BASIC lNFORMATJON Facilit)1 Name: Ascent Resources -Ace Wel1 Pad Facility Location: 40.280324, -81.06844, Cadiz, Ohio Date oflnspection: April 16, 2019 EPA Inspectors: 1. Constantinos Loukeris, Environmental Engineer 2. Victoria Nelson, Environmental Engineer 3. Natalie Topinka, Environmental Scientist Other Attendees 1. Jon Hickman, EH&S Supervisor - Environmental, Ascent 2. Dustin Daugherty, FLIR'~' technician, Ascent 3. Laine Crawford, Ascent 4. Mike Neptune, Ascent Contact Email Address: jon.hickman@ascentresources.com Purpose of Inspection: to assess compliance \.Vith requirements of NSPS S1.,1bpart 0000 and facility PTIO Facility Type: oil and natural gas well pad Regulations Central to Inspection: New Source Performance Standards (NSPS) Subpart 0000 Arrival Time: 2:08 pm Departure Time: 2:46 pm Inspection Type: D Unarmounced Inspection l:2l Announced Inspection OPENING CONFERENCE l:2l Credentials Presented l:2l CBI warning to facility provided The following information was obtained verbally from Ascent representatives unless otherwise noted. Company Ownership: Ascent Resources acquired this well pad from Hess Corporation in approximately November 2018. Process Description: At the well pad, an oil/gas/water emulsion is extracted from the formation through wells on-site. 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-baITel, 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 captnre system and combustor to accommodate Staff Interview: The Ace well pad has three wells and four tanks: one produced water tank and three condensate tanks. Each well pad produces about ten baITels per day. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: We climbed the tank battery and viewed the thief hatches and pressure relief devices with the FUR GF-320 camera (FUR camera). We did not detect emissions via olfactory, visual, or auditory methods. We observed emissions with the FUR camera from the emergency pressure relief hatch (EPRV) on the water tank and confim1ed the presence of volatile organic compounds (VOC) in the emissions plume using the Photo Ionization Detector (PID). Page 2 of 5 We also observed emissions with the FLIR camera from the BTEX condenser vent in the dehydration area. Ascent personnel indicated that it was a pressure relief valve that was venting/leaking to atmosphere. Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Requested documents: We reqnested the following documents, and summarized via e-mail on April 23, 2019: Ascent's flow chart for its LDAR program (i.e. chain ofresponsibility and procedures/tasks). Records ofLDAR/FLIR" surveys, repairs, and follow-up verifications conducted at Ascent's Foxtrot well pad since its acquisition from Hess. A repair log (date/FUR" verification) for the items (i.e. weighted hatches, conservation vents, vacuum breakers, and threaded com1ections) EPA noted to be emitting during our inspections on Ap1il 16-17, 2019. A copy of the spec sheet for the combustor installed at the Grywalski well pad. We also requested feedback on the following additional topics we discussed for consideration: Explore using existing pressure gauges on tank vapor space to inform operators of what sort of conditions the tanks undergo throughout dump cycles and in a variety of temperature conditions. The pressure data could be used to inform operators of what kinds of stress the pressure/vacuum relief devices experience, and potential options for alleviating that stress to prevent emissions/leaks. Would Ascent consider installing pressure gauges on existing tank batteries, or include them in the design of new well pads pending construction? Assess the gasket material on every tank hatch that was acquired from Hess and switch out to known higher-perfom1ing material if not done so yet. How are VOC emissions that occur from BTEX condenser vents on dehydration equipment (e.g. what was observed on the Ace pad) tracked and accounted for? Ascent responded via e-mail on May 9, 2019. Compliance Assistance: We discussed the items listed above as ways to inform continuous improvement of Ascent's operations and LDAR program. Page 3 of5 Concerns: Where we detected emissions with the FUR camera, we shared our observations with Ascent personnel, so the leak point could be tagged for repair. SIGNATURES Report Author: _:-,._-----=---,,/'-------,,~-- Date: ___6/5,bol q Section Chief: --c~~~'_k',j'_.~~~~':':_'_ _ Date: - ~ ~ / ; ? Page 4 of 5 Facility Name: Ascent Resources -Ace Well Pad Facility Location: 40.280324, -81 .06844, Cadiz, Ohio Date of Inspection: April 16, 2019 APPENDICES AND ATTACHMENTS 1. Digital image/video log 2. Digital images and videos on CD Page 5 ofS Facility Name: Ascent Resources -Ace Well Pad Facility Location: 40.280324, -81.06844, Cadiz, Ohio Date of Inspection: April 16, 2019 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Constantinos Loukeris 3. Company/Facility Name: Ascent Resources - Ace Well Pad 5. Number of Images: 5 Image Number File Name 1 MOY 2264.rnp4 2 MOV 2265.mp4 3 MOV 2266.mp4 4 MOV 2267.rnp4 5 MOV 2268.mp4 2. Date(s) of Inspection: April 16, 2019 4. Street Address, City, State: 40.280324, -81.06844, Cadiz, Ohio 6. Archival Record Location: CD-R labeled "Ascent Resources -Ace Well PadInspection photos/video 4/16/2019" Date 4/16/19 4/16/19 4/16/19 4/16/19 4/16/19 Description of Image VOC emissions imaged from the Model 2008 weighted thief hatch on the Condensate tank furthest away from the Produced Water tank. VOC emissions imaged from the Model 2008 weighted thief hatch on the Condensate tank next to the Produced Water tank. voe emissions imaged from the Model 2008 weighted thief hatch on the Produced V/ater tank. VOC emissions imaged from the vacuum breaker on the Produced Water tank. voe emissions imaged from the BTEX condenser vent. The pressure relief valve was leaking/venting. Appendices Page 1 of 1