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Home My WebLink AboutDAQ-2024-0046021 DAQC-CI156680001-24 Site ID 15668 (B1) MEMORANDUM TO: FILE – WATER DISPOSAL INC. – Produced Water Facility THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Kyle Greenberg, Environmental Scientist DATE: January 5, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Duchesne County INSPECTION DATE: September 6, 2023 SOURCE LOCATION: SE-NW Sec 32 T1S R1W Duchesne County, UT DIRECTIONS: Latitude: 40.354049; Longitude: -110.022373 SOURCE CONTACTS: Doug Betts, Owner: karldouglasbetts@yahoo.com 435-724-1165 OPERATING STATUS: Operating PROCESS DESCRIPTION: Produced water is received by truck from oil and gas operations. The water then undergoes phase separation using tanks and centrifuges for the recovery of oil and condensate. The remaining water is then injected into a well on site. Recovered oil and condensate is stored on site in tanks prior to being trucked off site for sale. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN156680001-17, dated May 24, 2017 SOURCE EVALUATION: Name of Permittee: Permitted Location: Water Disposal Inc. - Produced Water Facility 2285 Lucky John Drive SE-NW Sec 32 T1S R1W Park City, UT 84060 Duchesne County, UT SIC Code: 1389: (Oil & Gas Field Services, NEC) Section I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] 2 I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: Out of Compliance with Conditions I.3, I.4, I.5, and I.7. Equipment on-site does not match up with the equipment and processes approved in this AO. The process observed during the time of the inspection are not consistent with good air pollution control practice for minimizing emissions. Records have not been kept and an emissions inventory has not been submitted. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 WDI- Produced Water Facility Produced Water Treatment Facility II.A.2 Fourteen (14) Storage Tanks Maximum capacity: 1000 bbl (each) All controlled by combustor II.A.3 Two (2) Injection Storage Tanks Maximum capacity: 500 bbl (each) All controlled by combustor II.A.4 Four (4) Oil Storage Tanks Maximum capacity: 500 bbl (each) All controlled by combustor II.A.5 Two (2) Skimming Containers Covered and controlled by combustor 3 II.A.6 Two (2) Mixing Tanks Covered and controlled by combustor II.A.7 Sealed Solids Storage Contents: Sludge from tanks, centrifuges, etc. Controlled by combustor II.A.8 One (1) Combustor II.A.9 Tank Heaters Maximum rated capacity: less than 5.0 MMBtu/hr (each) Fuel: Natural Gas II.A.10 Miscellaneous Equipment Various small engines listed under 25 hp Status: There are two 400 bbl fresh water tanks, four 400 bbl overflow tanks, three 1,000 bbl water tanks, five 500 bbl injection storage tanks, four 500 bbl oil storage tanks, one skimming container, one combustor, three line-heaters, four 0.5 MMBtu/hr tank heaters, and various small electric engines on-site. The discrepancy of equipment listed in the AO versus the equipment on-site has been addressed in a Compliance Advisory (DAQC-992-23). II.B Requirements and Limitations II.B.1 Source-Wide Requirements II.B.1.a The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] II.B.1.b Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any stationary point or fugitive emission source on site to exceed 10 percent opacity. [R307-401-8] II.B.1.b.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3] Status: Out of Compliance with Condition II.B.1.a, the owner/operator did not submit documentation of the status of construction or modification to the director within 18 months from the date of this AO. A compliance advisory (DAQC-992-23) has been issued regarding this matter. No visible emissions greater than 10 percent opacity were observed during the time of inspection. II.B.2 Tank Requirements II.B.2.a The owner/operator shall not produce more than 14,400 barrels (1 barrel = 42 gallons) of crude oil per rolling 12-month period. [R307-401-8] II.B.2.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the last day of each month using the most recent 12 months of sales data recorded via sales receipts. Records of crude oil sales shall be kept for all periods when the plant is in operations. [R307-401-8] 4 II.B.2.b Centrifuge solids and tank sludge shall be stored in an enclosed storage vessel prior to being hauled off site. [R307-401-8] II.B.2.b.1 All sludge and centrifuge waste shall be contained in the enclosed storage vessel at the end of each business day. Records of sludge and centrifuge waste deposits shall be kept for all periods when the plant is in operation. Deposits shall be determined by supervisor monitoring and maintaining an operations log. [R307-401-8] II.B.2.c The secondary containment located under and around the centrifuges shall have no standing crude oil or solids present at any time. In lieu of maintaining a clean secondary containment, the source may construct an enclosure around the centrifuges and route all building emissions to the operating combustor. [R307-401-8] II.B.2.d The owner/operator shall load and unload all tanker trucks on site by the use of submerged loading. [R307-401-8] II.B.2.e The owner/operator shall keep the storage tank thief hatches closed and latched except during tank loading, unloading, or other maintenance activities. [R307-401-8] II.B.2.f The owner/operator shall inspect the thief hatches at least once monthly to ensure the thief hatches are closed, latched, and the associated gaskets, if any, are in good working condition. Records of thief hatch inspections shall include the date of the inspection and the status of the thief hatches. [R307-401-8] Status: Out of Compliance with Conditions II.B.2.a, II.B.2.b, II.B.2.b.1, and II.B.2.f. The owner/operator has produced more than 14,400 barrels of crude oil per rolling 12-month period. Centrifuge solids and tank sludge are not stored in an enclosed storage vessel prior to being hauled off site. All sludge and centrifuge waste are not contained in the enclosed storage vessel at the end of each business day. Records of sludge and centrifuge waste deposits have not been kept for all periods when the plant is in operation. Deposits have not been determined by supervisor monitoring nor has an operations log been maintained. Thief hatches are not inspected monthly nor are thief hatch inspection records kept. A compliance advisory (DAQC-992-23) has been issued regarding these matters. Submerged loading is used during loading and unloading operations and all thief hatches were closed during the time of inspection. II.B.3 Combustor Requirements II.B.3.a All exhaust gas/vapors from all storage tanks and the sealed solids storage shall be routed to the operating combustor within 120 days from the issuance of this AO. [R307-401-8] II.B.3.b The combustor shall operate with a continuous pilot flame and be equipped with an operational auto-igniter. [R307-401-8] II.B.3.c The combustor shall operate with no visible emissions. [R307-401-8] II.B.3.c.1 Visual determination of smoke emissions from the combustor shall be conducted according to 40 CFR 60, Appendix A, Method 22. [R307-401-8] Status: Out of Compliance with Condition II.B.3.a. The open air mixing tanks and the sludge from tanks and centrifuge waste are not controlled by the combustor. A compliance advisory (DAQC-992-23) has been issued regarding these matters. The combustor was lit and operating during the time of inspection. All other tanks were routed to the combustor. The combustor was operating with no visible emissions during the time of inspection. II.B.4 Haul Road Requirements II.B.4.a The owner/operator shall comply with all applicable requirements of R307-205 for Fugitive Emission and Fugitive Dust sources on site. [R307-205] 5 II.B.4.b Visible emissions from haul roads and fugitive dust sources shall not exceed 20 percent opacity. [R307-401-8] II.B.4.b.1 Visible emission determinations for fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-401-8] II.B.4.c A maximum haul road speed limit of 15 miles per hour shall be posted, at a minimum, at the beginning of the haul road where it is clearly visible. [R307-401-8] II.B.4.d All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed to control fugitive dust. The application of water shall be used except when the ambient temperature is below freezing. Treatment shall be of sufficient frequency and quantity to meet the opacity limits listed in this AO, or as determined necessary by the Director. [R307-401-8] II.B.4.d.1 Records of water treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date of treatment B. Number of treatments made C. Records of temperature if the temperature is below freezing [R307-401-8] Status: Out of Compliance with Condition I.B.4.d.1. Records of water treatment of the roads have not been kept. A compliance advisory has been issued (DAQC-992-23). There were no visible emissions from the haul roads during the time of inspection and there is a water truck on-site. The haul road speed limit is below 15mph. AREA SOURCE RULES EVALUATION: EMISSION INVENTORY: The emissions listed below are an estimate of the total potential emissions (PTE) from Water Disposal Inc. Produced Water Facility on the Approval Order (AO) DAQE-AN156680001-17, dated May 24, 2017. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr CO2 Equivalent 1557.00 Carbon Monoxide 2.22 Nitrogen Oxides 0.74 Particulate Matter - PM10 0.23 Particulate Matter - PM2.5 0.02 Sulfur Dioxide 0.02 Volatile Organic Compounds 24.28 Hazardous Air Pollutant PTE lbs/yr Benzene (Including Benzene From Gasoline) (CAS #71432) 80 Ethyl Benzene (CAS #100414) 40 Generic HAPs (CAS #GHAPS) 388 Methanol (CAS #67561) 2 Toluene (CAS #108883) 110 Xylenes (Isomers And Mixture) (CAS #1330207) 200 6 PREVIOUS ENFORCEMENT ACTIONS: - An early settlement agreement was issued March 3, 2017, due to not submitting a Notice of Intent (NOI) and operating without an Approval Order (AO). - A compliance advisory was issued September 14, 2023. - An early settlement agreement was issued December 22, 2023. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN156680001-17, dated May 24, 2017: Out of Compliance. A compliance advisory (992-23) and an ESA (1359-23) have been issued. The source is working on getting back in compliance and working with a consultant in regards to issuing a NOI to address the production limit and equipment list. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: It is recommended to look for progress regarding the NOI before the next inspection. NSR RECOMMENDATIONS: It is recommended the source issue a NOI regarding the production limit and discrepancy in the equipment on-site versus the equipment listed in the AO. ATTACHMENTS: N/A.