Document 6RDpmrdwybrK47JO2d4pJZKV6
DATE: SUBJECT: FROM: THRU: TO:
UNITED STATES El\'VIRONMENTAL PROTECTION AGENCY REGIONS
77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604
OCT 2 8 2019
CLEAN AIR ACT INSPECTION REPORT Antero Resources (Antero)-Andes Well Pad, Quaker City, Ohio
Constantinos Loukeris, Environmental Engineer AECAB (MI/WI)
Ethan Chatfield, Acting Section Chief AECAB (MI/WI)
File
BASIC INFORMATION
Facility Name: Antero Resources (Antero)-Andes Well Pad
Facility Location: Quaker City, Ohio
Date of Inspection: August 29, 2019
EPA Inspectors: I. Constantinos Loukeris, Environmental Engineer
Other Attendees I. Lou Ann Lee, Environmental Field Supervisor, Antero 2. Doug Stebbins, Production Superintendent, Antero 3. Mark Hertzler, Production Supervisor, Antero 4. Eddy Grenert, Field Production Engineer, Antero 5. Gary Stephens, Production Roustabout, Antero 6. Bob Lucas, Production Roustabout, Antero 7. Jeremy Kinney, Environmental Field Specialist II, Antero 8. Ken Callaway- Production FSS, Contractor to Antero
Contact Email Address: llee@anteroresources.com
Purpose of Inspection: to assess compliance with requirements ofNSPS Subparts OOOO/OOOOa and facility PTIO
Facility Type: oil and natural gas well pad
Regulations Central to Inspection: New Source Performance Standards (NSPS) Subparts 0000 and OOOOa
Arrival Time: 5:15 pm Departure Time: 6:02 pm
Inspection Type:
D Unannounced Inspection
C2l Announced Inspection
OPENING CONFERENCE
C2l Credentials Presented C2l CBI warning to facility provided
The following information was obtained verbally from Antero representatives unless otherwise noted.
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-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: The Andes well pad has five wells and fourteen tanks.
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 FLIR GF-320 camera (FLIR camera). We observed emissions with the FLIR camera from emergency vents on water tanks and condensate tanks and confirmed the presence of volatile organic compounds (VOC) in the emissions plume using the photo ionization detector. This facility has five enclosed combustors, and VOC were imaged from the one of the five. In addition, Antero used a "zero emission" model Jayco thief hatch on several of the tanks at this pad. EPA did not observe VOC emissions from those thief hatches.
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Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection.
CLOSING CONFERENCE
Requested documents:
We requested the following documents, and summarized via e-mail on April 23, 2019:
Documentation from the last quarterly optical gas imaging inspection performed by
Antero at the well pads EPA inspected on August 29, 2019;
Well names associated with the well pads EPA inspected on August 29, 2019; Pressure settings for the thief hatch, emergency vent, conservation vent, vacuum breakers
for each tank/tank battery at the well pads EPA inspected on August 29, 20 19;
Antero indicated that all sites are complying with NSPS OOOO/OOOOa; however, based
on Antero's PTE calcs, which ones are required to comply with NSPS OOOO/OOOOa and which ones are not? Provide the emissions calcs for those Antero believes are not required to;
Model for Jayco "zero-emission" thief hatch that was observed at a few of the Antero well pads EPA inspected on August 29, 2019;
Arrangement and pressure settings of the 5 enclosed combustors at the Andes Well Pad, including how the vapor recovery systems;
Emission calcs associated with dump events and/or other malfunction events for the past 2 years at the well pads EPA inspected on August 29, 2019; and
Names and titles of those who participated on our well pad inspections (I don't believe I asked for this, but if you could please provide).
Antero responded with responses to each of the requested documents via e-mail on October 2 and 11, 2019.
Concerns: Where we detected emissions with the FUR camera, we shared our observations with Antero personnel, so the leak point could be tagged for repair.
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Facility Name: Antero Resources (Antero)-Andes Well Pad Facility Location: Quaker City, Ohio Date of Inspection: August 29, 2019
APPENDICES AND ATTACHMENTS
1. Digital image/video log 2. Digital images and videos on CD
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Facility Name: Antero Resources (Antero) - Andes Well Pad Facility Location: Quaker City, Ohio Date of Inspection: August 29, 2019
APPENDIX A: DIGITAL IMAGE LOG
1. Inspector Name:. Constantinos Loukeris
3. Company/Facility Name: Antero Resources (Antero) - Andes Well Pad
5. Number of Images: 8
Imao-e Number
File Name
I
MOV 2373.mn4
2
MOV 2374.mp4
3
MOV 2375.mn4
4
MOV 2376.mo4
5
MOV 2377.mn4
6
MOV 2378.mo4
7
MOV 2380.mo4
8
MOV 2381.mp4
2. Date(s) of Inspection:
Au011st 29, 2019 4. Street Address, City, State:
Quaker City, Ohio
6. Archival Record Location: CD-R labeled "Antero Resources -Andes Well Pad Insnection video 8/29/2019"
Date
8/29/2019 8/29/2019 8/29/2019 8/29/2019 8/29/2019 8/29/2019 8/29/2019
8/29/2019
Description of Image VOC emissions imaged from the conservation vent located above tank#14 on the pipe header to the
tank batterv. VOC emissions imaged from the
emergencv vent at tank#l4. VOC emissions imaged from the
emernencv vent at tank#2. VOC emissions imaged from the
emergencv vent at tank#l3. VOC emissions imaged from the
emergency vent at tank#l2. VOC emissions imaged from the
emernencv vent at tank#6. VOC emissions imaged from the high/low motor valve from vapor
recoverv unit 9693. VOC emissions imaged from one
of the five combustors.
Appendices Page 1 of l