Document VavmoO4DQGnb9NYL8Ge8nzpw

DATE: SUB.JECT: FROM: TH.RU: TO: UN1TED STATES ENVlH.ON~..lENTAL PROTECTION A.GENCY REGION 5 77 WEST .JACKSON BOl!LEVARD CHlCAGO, lLLlNOIS 60604 JUN O7 2019 CLEAN AIR ACT JNSPECTION REPORT Ascent Resources --Axle Well Pad, Warren, Ohio Constantinos Loukeris, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Chief AECAB (Ml/WI) File BASIC INFORMATION Facility Name: Ascent Resources -Axle Well Pad Facility Location: 39.983407, -81.19732, Warren, Ohio Date of Inspection: April 17, 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 with requirements of NSPS Subpart 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: 9:36 am Departure Time: 10: 15 am Inspection Type: D Unannounced Inspection [gJ Announced Inspection OPENING CONFERENCE [gJ Credentials Presented [gJ 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-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 Axle well pad has four wells and four tanks: one produced water tank and three condensate tanks. TOUR INFORM.ATl ON 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 can1era from the emergency pressure relief hatch (EPRV) on the water tank and confirmed the presence of volatile organic compounds (VOC) in the emissions plume using the Photo Ionization Detector (PID). EPA observed a Page 2 of 4 smoking (i.e. black smoke) flare for the periods of9:36 am - 9:38 am with a 20 second gap where the flare wasn't smoking and again at 9:43 am - 9:45 am. Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. CLOS!NC CONFERENCE Requested documents: We requested the following documents, and summarized via e-mail on April 23, 2019: Ascent's flow chart for its LDAR program (i.e. chain of responsibility 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 connections) EPA noted to be emitting during our inspections on April 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 infom1 operators of what s01i of conditions the tanks nndergo 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-perfonning 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 of 5 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. Date: Page 4 ofS Facility Name: Ascent Resources -Axle Well Pad Facility Location: 39.983407, -81.19732, Warren, Ohio Date oflnspection: April 17, 2019 APPENDICES AND ATTACHMENTS I. Digital image/video log 2. Digital images and videos on CD Page 4 of.!!; Facility Name: Ascent Resources -Axle Well Pad Facility Location: 39.983407, -81.19732, Warren, Ohio Date of Inspection: April 17, 2019 APPENDIX A: DIGITAL IMAGE LOG l. Inspector Name: Constantinos Loukeris 3. Company/Facility Name: Ascent Resources -Axle Well Pad 5. Number of Images: 7 Image Number File Name 1 MOY 2287.mp4 2 MOY 2288.mp4 .") MOY 2289.mp4 4 MOV 2291.mp4 5 MOY 2293.mp4 6 MOV 2294.mp4 7 MOY 2295 .mp4 2. Date(s) of Inspection: April 17, 2019 4. Street Address, City, State: 39.983407, -81.19732, Warren, Ohio 6. Archival Record Location: CD-R labeled "Ascent Resources -Axle Well PadInspection photos/video 4/17/2019'' Date 4/17/19 4/17/19 4/17/19 4/17/19 4/17/19 4/17/19 4/17/19 Description of Image VOC emissions imaged from the base of the conservation vent on the Condensate tank fmihest away from the Produced Water tank. VOC emissions imaged from the Model 2008 weighted thief hatch on the middle of the three Condensate tanks. VOC emissions imaged from the consenration vent on the Condensate tank next to the Produced Water tank. VOC emissions imaged from the Model 2008 weighted thief hatch on the Condensate tank next to the Produced Water tank. VOC emissions imaged from the head of the vacuum breaker on the Condensate tank next to the Produced Water tank. VOC emissions imaged from the Model 2008 weighted thief hatch on the Produced Water tank. VOC emissions imaged from the conservation vent on the Produced \\later tank. Appendices Page 1 of 1