Document npEwRD4OZ5DQD0OrY82R0xQE2

DATE: SUBJECT: FROM: THRO: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 JUN O4 2019 CLEAN AIR ACT INSPECTION REPORT Utica Resource Operating, LLC- Garvin Well Pad, Wills Township, Ohio Victoria Nelson, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Chief AECAB (MI/WI) File BASIC INFORMATION Facility Name: Utica Resource Operating, LLC-Garvin Well Pad Facility Location: 39.56399, -81.5081, Wills Township, Ohio Date of Inspection: April 18, 2019 EPA Inspectors: 1. Victoria Nelson, Environmental Engineer 2. Natalie Topinka, Environmental Scientist 3. Constantinos Loukeris, Environmental Engineer Other Attendees: 1. Maureen Kertes, EHS Professional, URO 2. Shannon Thompson, KC Harvey Contact Email Address: mkertes@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: 4:16 PM ET Departure Time: 4:40 PM ET Inspection Type: D Unannounced Inspection 121 Announced Inspection OPENING CONFERENCE 121 Credentials Presented 121 CBI warnmg to facility provided The following information was obtained verbally from Ms. Kertes unless otherwise noted. Company Ownership: This well pad, along with IO 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 three wells, located near the Garvin well pad. 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 a tank battery with separate 400or 500-barrel, atmospheric pressure, fixed-roof tanks on-site. The tank battery is made up of six tanks and was connected to three low pressure towers. 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: URO recently received a license for ProMax software to begin modeling emissions from well pads. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: From ground level, we could smell a hydrocarbon odor and see visible vapors (i.e. refraction) from the tattles. The tank battery was connected to three low pressure towers (alca vapor recovery towers), although we could not discern by observation if they were operating at the time of our inspection. The combustor was not operating, although emissions from the top of the stack were visible with the FLIR camera. 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). The combustor was located downhill from the Page 2 of 4 tank battery in a gully. EPA could not tell if the tank battery was piped to the combustor. Only the lines from the three separators appeared to go to the combustor. Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Compliance Assistance: We shared what we observed with the FUR 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 information and knowledge about how the facilities were constructed and are currently operated. SIGNATURES Page 3 of 4 Facility Name: Utica Resource Operating, LLC - Garvin Well Pad Facility Location: 39.56399, -81.5081, Wills Township, Ohio Date of Inspection: April 18, 20 I 9 APPENDICES AND ATTACHMENTS I. Digital image/video log Page 4 of 4 Facility Name: Utica Resource Operating, LLC- Garvin Well Pad Facility Location: 39.56399, -81.5081, Wills Township, Ohio Date of Inspection: April 18, 2019 APPENDIX A: DIGITAL IMAGENIDEO LOG 1. Inspector Name: Victoria Nelson 3. Company/Facility Name: Utica Resource Operating, LLC Garvin Well Pad 5. Number of Images and Videos: 9 2. Dates of Inspection: April 18, 2019 4. Street Address, City, State: 39.56399, -81.5081, Wills Township, Ohio 6. Archival Record Location: C:\Users\Vnelson\OneDrive - Environmental Protection Agency (EPA)\MyCases\Utica Resource\Inspection Reports Video Number 1 File Name Date MOV_2416.mp4 4/18/2019 Description of Video Emissions from water condensate tank thief hatch 2 MOV 2417.mp4 4/18/2019 Emissions from Tank 2269 thief hatch 3 MOV 2418.mp4 4/18/2019 Emissions from Tank 2267 thief hatch 4 MOV_2419.mp4 4/18/2019 Emissions from combustor - combustor was not operating 5 MOV 2420.mp4 4/18/2019 Emissions from 2-H Separator during dump Image Number 1 File Name P4180045.JPG 2 P4180046.JPG 3 P4180047.JPG 4 P4180048.JPG Date and Time (Eastern Time) 4/18/2019 4:34:39 PM 4/18/2019 4:35:12 PM 4/18/2019 4:36:50 PM 4/18/2019 4:36:55 PM Latitude and Longitude 39.56322, -81.507512 39.563047, -81.507435 39.563405, -81.507602 39.563405, -81.507602 Description of Image Line to combustor in gully View of combustor, access road, and tank battery Line leading to base of combustor Line from combustor leading to separators Appendices Page 1 of 1