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Home My WebLink AboutDAQ-2024-0082911 DAQC-PBR100677001-24 Site ID 100677 (B1) MEMORANDUM TO: FILE – FINLEY RESOURCES INC. – Deep Creek Tribal 27-09-4-2E THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Chris Jensen, Environmental Scientist DATE: June 4, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: May 22, 2024 SOURCE LOCATION: Deep Creek Tribal 27-09-4-2E Lat:40.10554 Long: -109.74329 Business Office: 1308 Lake Street Fort Worth, TX 76102 SOURCE TYPE: Tank Battery Uintah County API: 43047-56721 SOURCE CONTACTS: Aimee Cole, Local Contact Phone: 720-384-7365, Email: acole@finleyresources.com OPERATING STATUS: Operating PROCESS DESCRIPTION: Oil and gas products are brought to the surface. These products go through a separator where the oil and any water products are sent to storage tanks and the gas is used to power equipment on site (pump jack engine, tank heater, separator, flare, combustor, etc.) Any remaining gas is sent to a pipeline that feeds a local gas plant. The oil and process water in the storage tanks is loaded into tanker trucks and hauled off-site for processing and disposal. APPLICABLE REGULATIONS: Utah Administrative Code (UAC) R307-500 Series for the Oil and Gas Industry, and UAC R307-201: Emission Standards: General Emission Standards; and UAC R307-150: Emission Inventories, 40 CFR 60 Subpart OOOOa and 40 CFR 60 Subpart JJJJ. SOURCE EVALUATION: Site Type: PBR- Controlled Controlled by flare Site powered by Engine The source registered: 182500 Estimated Oil BBL. 2 DOGM current 12 month rolling production is: 12,365 BBLS. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Engine - Engine - Natural Gas 4-Stroke Rich Burn Make - Caterpillar Model - G3412 Mfg Year - 2011 Horse Power - 603 Combustion - Field Gas, Pneumatic, Tank. This engine is not as registered. It is an Ajax E-565. General Provisions VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] In Compliance. Air pollution control equipment is designed and installed appropriately, maintained and operated to control emissions. [R307-501-4(2)] In Compliance. Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-2] In Compliance. Vessel lines are properly sloped. Flare inlet lines are equipped with a fire arrestor, pressure gauge, inlet pressure regulating valve and other components according to the engineering design, the manufacturers specifications or good practices for safety and emissions control. [R307-501-2] In Compliance. Pneumatic Controllers Flares Any flare has an operational auto-igniter. [R307-503-4] In Compliance. Inspection of source reveled auto-igniter installed on flare. Tank Truck Loading Truck loading is done by bottom filling or submerged fill pipe. [R307-504(1)] In Compliance. Source is set up for bottom or submerged filling. A vapor capture line is used during truck loading if subject to storage vessel emissions controls of R307-506-4(2). Effective 7/1/2019 for sources existing before 1/1/2018, and upon construction for new sources. [R307-504-4(2)] In Compliance. Vapor capture line found installed and available for use. 3 Oil and Gas Industry Registration Requirement The source is registered with the DAQ. [R307-505-3(3)] In Compliance. Search of DAQ records shows source is properly registered. Registration has been updated within 30 days of a company name change, removal or addition of control devices, or termination of operations. [R307-505-3(3)] In Compliance. Storage Vessels Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. Thief hatches found closed and latched at the time of inspection. VOCs from storage vessels are recycled, recovered or controlled by a device that is compliant with R307-508. Exempt if <8000 bbls crude oil per year, <2000 bbls condensate, or if uncontrolled emissions are <4 tons VOC per year. [R307-506-4(2)(a)] In Compliance. VOC's captured and sent to control device. Emissions from emergency storage vessels are controlled according to R307-506-4(2), or are only used in emergencies, are emptied within 15 days of receiving fluids and are equipped with a liquid level gauge. [R307-506-4(4)] In Compliance. Emergency storage vessel found free of emissions and properly controlled. Upon modification, the well site was re-evaluated against the thresholds of R307-506-4(2). [R307-506-4(6)] In Compliance. No modifications to this source were found at the time of inspection. Records for each of the following are kept for three years: Storage vessel vent system inspections (openings, thief hatches, pressure relief devices, bypasses, etc.), if required Monthly crude oil throughput Emission calculations, actuals and sampling data when used to justify an exemption to storage vessel rules Emergency storage vessel usage (dates used, emptied, and volumes), if not controlled per R307-506-4(2). [R307-506-5] In Compliance. DAQ inspector has reviewed these documents and found them compliant. 4 VOC Control Devices The VOC control device(s) required by R307-506 or R307-507 has a control efficiency of 95% or greater, operates with no visible emissions and has an operational auto-igniter according to R307-503. [R307-508-3(1)] In Compliance. No visible emissions were observed at the time of inspection. Monthly AVO inspections are conducted on VOC control devices and associated equipment, and corrective actions are taken within 15 days. [R307-508-3(3)] In Compliance. DAQ inspector has reviewed these documents and found them compliant. The following records are kept: VOC control device efficiency, for life of the equipment Manufacturer operating and maintenance instructions for VOC control devices, for life of the equipment AVO inspections of the VOC control device(s), associated equipment and any repairs, for 3 years. [R307-508-4] In Compliance. DAQ inspector has reviewed these documents and found them compliant. Leak Detection and Repair The source has an emissions monitoring plan. [R307-509-4(1)(a)] In Compliance. DAQ inspector has reviewed these documents and found them compliant. The monitoring plan addresses difficult-to-monitor and unsafe-to-monitor components. [R307-509-4(1)(b)] In Compliance. DAQ inspector has reviewed these documents and found them compliant. If emissions control is required, monitoring surveys are conducted to observe each fugitive emissions component for fugitive emissions. [R307-509-4(1)(c)] In Compliance. Initial monitoring surveys were within 60 days after startup for new sources. Subsequent surveys are semi-annual for regular components, annual for difficult-to-monitor components, and as required by the monitoring plan for unsafe-to-monitor components. [R307-509-4(1)(d)] In Compliance. Monitoring surveys are done with OGI equipment or by Method 21. [R307-509-4(1)(e)] In Compliance. 5 Fugitive leaks are repaired within 15 days unless infeasible, unsafe, etc., as stated in the rule, which require repair within 24 months per the rule. [R307-509-4(1)(f)] In Compliance. Reported leaks were addressed within 15 days. Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] In Compliance. The following records are kept: The emissions monitoring plan, for life of the site LDAR inspections, repairs and resurveys, for 3 years. [R307-509-5] In Compliance. DAQ inspector has reviewed these documents and found them compliant. Natural Gas Engines Engines subject to R307-510 (does not have an AO, began operations, installed or modified after January 1, 2016) meet the following limits: Maximum Engine hp Emission Standards in (g/hp-hr) NOx CO VOC HC+NOx >25 hp and < 100 hp - 4.85 - 2.83 >100 hp 1.0 2.0 0.7 - [R307-510-4(1)] In Compliance. Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)] In Compliance. The Operator has now completed the performance testing of this engine, Ajax E-565, in September 2023. Affected engine exhaust vents are vertical and unrestricted. Stacks are 8' or greater if the site horsepower rating is 151 to 305 Stacks are 10' or greater if the site horse power rating is 306 or greater. [R307-510-4(3)] In Compliance. Exhaust was corrected to vertical on July 25, 2023. Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. This has now been done and the result report is kept. 6 Associated Gas Flaring Associated gas is routed to a process unit for combustion, a sales pipeline or an operating VOC control device, except in an emergency. An emergency release is unanticipated, temporary, infrequent, unavoidable, =24 hrs. and is not due to operator negligence. Low pressure gas from working loss, breathing loss and oil flashing is not "associated gas". [R307-511-4(1)] In Compliance. The following records are kept: The time and date of event Volume of emissions Any corrective action taken for 3 years. [R307-511-5(1)(a)(b)] In Compliance. Visible Emissions Visible emissions, except for unavoidable irregularities that do not exceed three minutes, are within the following opacity limits: Installations constructed on or before 4/25/1971 40% Installations constructed after 4/25/1971 20% Gasoline engines 0% Diesel engines manufactured after 1/1/1973 20% Diesel engines manufactured before 1/1/1973 40% Note: Required VOC control devices shall have no visible emissions per R307-508-3. [R307-201-3] In Compliance. No visible emission observed at the time of inspection. Emission Inventory: An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. Source startup date is October 28, 2021, and has not been subject to an emissions inventory. Applicable Federal Regulations: NSPS (Part 60) OOOOa: Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015. In Compliance. This source has an Approval (PBR) from the State of Utah with legal and enforceable limits. This source is exempt from OOOOa for the collection of fugitive emissions components. A monitoring, repair, and record keeping program is in place that would satisfy the requirements of 40 CFR (60) OOOOa for the collection of fugitive emissions components, closed vent system, and storage vessel facilities. See above evaluations. There are no other affected facilities installed. 7 NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. In Compliance. Now that the initial performance test has been conducted, the Ajax E-565 engine is compliant. PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. Although last year’s inspection did find it out of compliance for recordkeeping and not having an engine performance test. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to: Deep Creek Tribal 27-09-4-2E: In Compliance - The source was surveyed by AVO, and with an OGI camera, was found to be well-kept with no visible or fugitive emissions. Requested records were provided in a timely manner and reviewed at the local office. This source is a multi- well pad and has the production to require controls. It also seems to be double registered. The other well is also singly registered as PBR 8057. Karen Pratt (Finley Resources) and Stephen were written to about the duplicate registration so this error could be corrected. RECOMMENDATION FOR NEXT INSPECTION: The DAQ has no Recommendations for the next inspector other than what are customary. The DAQ recommends the inspection frequency of this source remain on a more frequent schedule. The DAQ imported the last inspection and noted the corrections made to come into compliance. ATTACHMENTS: None.