DAQ-2024-007282

State of Utah
SPENCERJ, COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Execative Drector
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
October 30,2023 DAQC-1rsg-23
Site ID: 15731 (B1)
Sent Via Certified Mail No. 70190700000208346122
Tony Cook
Wolverine Oil and Gas Company of Utah,LLC
55 Campau NW
Grand Rapids, Michigan 49503
Dear Mr. Cook:
Re: Early Settlement Agreement - Wolverine Oil and Gas Company of Utah LLC - Covenant
Field Production Facility - Sevier County
On August 16,2023, the Utah Division of Air Quality (DAQ) issued a Compliance Advisory to
Wolverine Oil and Gas Company of Utah LLC Covenant Field Production Facility as a result of
an inspection performed on August 9,2023. Wolverine Oil and Gas Company of Utah LLC
responded to the Compliance Advisory on September 12,2023. Based on the findings of the
inspection and response to the Compliance Advisory, the DAQ determined that Wolverine Oil and
Gas Company of Utah LLC was in violation of:
L Condition 1I.8.7.b.2 of Approval Order DAQE-ANI57310001-18
A leak was found from Tank 102 during the inspection and previous VOC monitoring
surveys were not conducted using one or both of the following to detect fugitive
emissions:
A. Optical gas imaging (OGD equipment. OGI equipment shall be capable of imaging
gases in the spectral range for the compound of highest concentration in the potential
fugitive emissions.
B. Monitoring equipment that meets U.S. EPA Method 21,40 CFR Part 60, Appendix A.
Section lg-2-115 of the Utah Code provides that violations of the Utah Air Conservation Act (the
Act) and/or any order issued thereunder may be subject to a civil penalty of up to $10,000 per day
for each violation. Based upon our civil penalty policy, we calculated a preliminary civil penalty
for the above listed violation of $2,000.
195 Norttr 1950 West. Salt Lake City, UT
Mailing Address: P.O. Box 144820. Salt Lake City, UT 84114-4820
Telephone [phone] . Fax [phone] . T.D.D. [phone]
w.deq.utah.gov
Printed on l00o/o recycled paper
DAQC-I1s9-23
Page2
The monetary amount of the DAQ settlement offer specified below is derived from a pre-
established schedule of penalties, which takes into account, among other factors, the magnitude
and severity of the violation, economic benefit, cooperation of the source as well as the prior
history of violations. See the attached penalty worksheet for details.
All parties we deal with, whether private, commercial, or governmental are treated similarly in the
settlement process. Early Settlement Agreements are based on the evaluation of the same factors
and criteria in all cases. The DAQ acknowledges that the violation on August9,2023,was
addressed by Wolverine Oil and Gas Company of Utah by updating the company's LDAR
program to be conducted with an OGI camera, fixing the leak from Tank 102, andpreemptively
planning to change the equipment that failed on Tank 102 to all other tanks onsite, in November
2023; to preemptively prevent a similar leak from occurring in the future.
If you are interested in settling this violation, we are authorized to offer settlement in accordance
with the DAQ Penalty Policy as follows:
1. Wolverine Oil and Gas Company of Utah agrees to pay a reduced civil penalty in the sum
of $1,600. Payment of a civil penalty precludes further civil enforcement for the above
described violation against the named source. Wolverine Oil and Gas Company of Utah
agrees to pay $1,600 of the stipulated penalty within twenty (20) business days from the
date you receive this Early Settlement Agreement.
2. The DAQ retains its authority to take any enforcement actions based on any and all
violations not specifically described above. If a violation is a failure to submit a Notice of
lntent to the Director and receive an Approval Order under Utah Administrative Code
R307-401-5, the DAQ retains its authority to take subsequent enforcement action if during
the next inspection the DAQ finds the source is still not in compliance with R307-401-5.
3. ln the event any further violations of the Act, the Utah Air Quality Rules, the source's AO,
or the Director's Orders occur, the DAQ may consider the violation described above in
assessing a penalty for the subsequent violations, in accordance with the provisions of
Utah Administrative Code R307- 1 30.
4. Entering into this Early Settiement Agreement shall not constitute an admission of
violation of the Act, the Utah Air Quality Rules, or the source's AO nor shall it be inferred
to be such an admission in any administrative or judicial proceeding. The described
violation will constitute part of the company compliance history for any purpose for which
such history is relevant to the DAQ.
At the DAQ's option, you may request a portion of the calculated civil penalty gravity component
to be used to complete a Supplemental Environmental Project (SEP) or credited toward the Utah
Environmental Mitigation Fund to benefit present and future air quality within Utah. For more
information, please contact the DAQ representative listed below.
DAQC-Irs9-23
Page 3
This Early Settlement Agreement constitutes an offer of settlement and is not a demand for
payment. The Early Settlement Agreement reflects a reduced penalty for early settlement of this
matter.
If the above terms are acceptable to you, please sign and return this Early Settlement Agreement
and a check in the sum of $1,600. Submit the signed Early Settlement Agreement and check made
payable to the DAQ at the letterhead address within twenty (20) business days of receipt of this
Early Settlement Agreement. Electronic payments are also available on our website at:
https ://deq.utah. gov/general/payment-portal.
You may write or call to request a settlement conference with the DAQ representative listed
below. A conference must be scheduled within twenty (20) business days of your receipt of this
Early Settlement Agreement. If we do not receive a signed copy of this Early Settlement
Agreement and payment or other correspondence from you within twenty (20) business days of
your receipt, we will assume that you are not interested in resolving this matter as outlined above.
If you need an Approval Order, this Early Settlement Agreement does not relieve you of that
responsibility and does not change that requirement in order to return to compliance with the
DAQ. You must submit a Notice of Intent for a required Approval Order as soon as possible.
Your source will be re-inspected in a reasonable time to confirm you have fully retumed to
operating in compliance. Failure to obtain a required Approval Order will subject you to
additional penalties and a new compliance action by the DAQ.
This Early Settlement Agreement is intended to quickly resolve the non-compliance issues listed
above and requires the immediate attention of your company. Failure to resolve this matter as
outlined above may result in this offer being revoked and/or having this matter referred to a
formal enforcement process, including filing a judicial case to collect penalties (up to $10,000 per
day for each violation) and compel compliance in the state district court.
If you have any additional questions regarding this matter, please contact Rik Ombach at
801-499-6095 or by email at [e-mail].
Sincerely,
4-.d
Bryce C. Bird
Director
BCB:RO:rh
cc: Central Utah Public Health Department
DAQC-I ts9-23
Page 4
Acceptance of Early Settlement Agreement
I have read the above Early Settlement Agreement and I agree to the terms and conditions thereof.
Company Name: Wolverine Oil and Gas Company of Utah LLC
Name:
Title:
Signature Date Telephone Number
DAQC-I rc9A3
Page 5
Wolverine Oil end
Gas Company of
Utah LLC-
Covenant Field
Production
Condition
II.B.7.b.2 of
Approval0rder
DAQE.
Ar\157310001-18
A leak was found
from Tank 102
duting the
inspection and
previous VOC
monitoring surveys
were not conducted
uslng elther
Method 21 or an
OGI Camera.
1 B
$2,000-
7,000
per
day
$2,000 $2,000
0
0
$2,000
$400
$1,600
R:i07-13G1.
Scope.
This policy provides guidance to the director in negotiating with air pollution sources penalties for
consent agreements to resolve non-compliance situations. It is designed to be used to determine a
reasonable and appropriate penalty for the violations based on the nature and extent of the violations,
consideretion of the economic benefit to the sources of non-compliance, and adjusments for specific
circumstances.
Rl07-13G2.
Categorics.
Violations are grouped in four general categories based on the potential for hatm and the nature and
extent of the violations. Penalty ranges for.each category are listed.
DAQC-Irs9-23
Page 6
(1) Category A. $7,000-10,000 per day.
Violations with high potential for impact on public health and the environment including:
(a) Violation of emission standards and
limitations of NESHAP.
(b) Emissions contributing to
nonattainment area or PSD increment
exceedances.
(c) Emissions resulting in documented public health effects
and/or environmental damage.
(2) Category B. $2,000-7,000 per day.
Violations of the Utah Air Conservation Act, applicable State and Federal
regulations, and orders to include:
(a) Significant levels of emissions resulting from violations of emission limitations or
other regulations which are not within Category A.
(b) Substantial non-compliance with
monitoring requirements.
(c) Significant violations of approval orders, compliance orders, and
consent agreements not within Category A.
(d) Significant and/or knowing violations of "notice of intent" and other notification
requirements, including those of NESHAP.
(e) Violations of reporting requirements
of NESHAP.
(3) Category C.Up to $2,000 per day.
Minor violations of the Utah Air Conservation Act, applicable State and Federal Regulations and orders
having no significant public health or environmental impact to include:
(a) Reporting
violations
(b) Minor violations of monitoring
requirements, orders and agreements
(c) Minor violations of emission
limitations or other regulatory
requirements.
DAQC-11s9-23
PageT
(4) Category D.Up to $299.00.
Violations of specific provisions of R307
which are considered minor to include:
(a) Violation of automobile emission
standards and requirements
(b) Violation of wood-burning regulations
by private individuals
(c) Open burning violations by private
individuals.
R307-130-3.
Adjustments.
The amount of the penalty within each category may be adjusted and/or suspended in
part based upon the following factors:
(l) Good faith efforts to comply or lack of good faith. Good faith takes into account the openness in
dealing with the violations, promptness in correction of problems, and the degree of cooperation with the
State to include accessibility to information and the amount of State effort necessary to bring the source
into compliance.
(2) Degree of willfulness and/or negligence. In assessing willfulness and/or negligence, factors to be
considered include how much control the violator had over and the foreseeability of the events
constituting the violation, whether the violator made or could have made reasonable efforts to prevent
the violation, and whether the violator knew of the legal requirements which were violated.
(3) History of compliance or non-compliance. History of non-compliance includes consideration of
previous violations and the resource costs to the State of past and current enforcement actions.
(4) Economic benefit of non-compliance. The amount of economic benefit to the source of non-
compliance would be added to any penalty amount determined under this policy.
(5) Inability to pay. An adjustment downward may be made or a delayed payment schedule may be used
based on a documented inability of the source to pay.
R307-130-4.
Options.
Consideration may be given to suspension of monetary penalties in trade-off for expenditures resulting
in additional controls and/or emissions reductions beyond those required to meet existing requirements.
Consideration may be given to an increased amount of suspended penalty as a deterrent to future
violations where
10120123,9:18 AM State of Utah Mail - Wolverine Update 8/14
Kyle Greenberg <[e-mail]>
Wolverine Update 8114
Tony Cook <[e-mail]>
To: Kyle Greenberg <[e-mail]>
Cc: Ed Higuera <[e-mail]>, Jordan Ritsema <[e-mail]>
Kyle,
Attached are 4 documents.
Tue, Sep 12,2023 at5:26AM
1. Providence Fleld, emergency generator log.
2. Covenant Field, Tank 102 hatch repair documentation.
3. Covenant Field, LDAR reports for September 2023.
4. Providence Field, LDAR reports for September 2Q23.
Covenant Field:
A leaking tank hatch was found on the produced oil tank #102 at the Covenant Field on Wednesday 819/23. The sealing surface of the
hatch was cleaned, and a new gasket was installed on Thursday 8/9/23. The field operators used gas detection equipment to
determine that the hatch repairs were successful. A gas imaging camera was reserved for 8/30 to confirm the leak was fixed. (See
attached repair documentation)
On9/6/23a Opgal EyeCGas imaging camera was used to confirm the hatch was repaired and no visible leaks were detected^
All of the Covenant Field wells were tested for leaks on9/5/23 using a Opgal EyeCGas imaging camera. Wolverine has now scheduled
testing of all of its equipment at the Covenant field to be completed every 6 months. Wolverine has reserved a gas imaging camera to
complete it's next testing in February 2024. (See attached LDAR reports)
An Approval Order Modification was sent to the state on 9172 to include the propane tank onto the equipment list on our air permit.
Providence Field:
All of the Providence Field wells were tested for leaks on9/t/23 uslng a Opgal EyeCGas imaging camera. Wolverine has now scheduled
testing of all of its equipment at the Providence field to be completed every 6 months. Wolverine has reserved a gas imaging camera
to complete it's next testing in February 2024. (See attached LDAR reports)
Regarding truck loading vapors at the Providence Field. We have now received all of the piping and valves needed to hook up the truck
loading vapors to the flare stack at the CPF. We will be working on installation of this over the next week.
hftps://mail.google.com/mail/u/0/?ik=83bbfebO',t*r;",,v=pt&search=all&permmsgid=msg-f:1776830916083475223&simpl=msg-f:1776830916083475223 112
10120f23,9:18 AM State of Utah Msil - Wolverine Update U14
An Approval Order Modification was sent to the state onglLlto include the backup generator onto the equipment list on our air
permit.
I have attached an hour log for the emergency generator as requested.
lf I have missed something, please let me know.
Thank you,
TnyE.?,ook
lQuoted ten hiddenl
4 attachments
{
Tank 102 LDAR.pdf
192K
Provldence laak Deteoflon lrcpedlons.pdf
4K
Covenant Leak Detecflon lnspectlon3.pdf
51K
Provldence Backup Generator Urage.pdf
76K
htps/matl.googlo.com/malUu0l?ik=83bbft&418&vl€u,=pt&searcfr=all&pormnsgE=msg+1776830916083475223&8imd=meg-f:1776830916083475223 2f2
t__
Wolverine Gas and Oil
Covenant Field
Leak Detection and Repair
September-23
Location
L Kings Meadow Ranches 17-1
2 Kings Meadow Ranches 17-14
3 Kings Meadow Ranches 17-20
4 Kings Meadow Ranches 17-21
5 Wolverine Federal 17-3
6 Wolverine Federal 17-4
7 Wolverine Federal 17-5
8 Wolverine Federal 17-6 (WF 8-1)
9 Kings Meadow Ranches 17-7
10 Wolverine Federal 17-11
11 Wolverine Federal 17-12
12 Wolverine Federal 17-13
13 Wolverine State 1,6-1
14 Wolverine Federal 17-17
15 Wolverine Federal L7-1-8
16 Wolverine Federal 17-19
l-7 Wolverine Federal 17 -2
18 Wolverine Federal 18-1
19 Wolverine Federal 19-1
20 Wolverine Federal 20-1
21 Wolverine Federal L7-8
22 Wolverine Federal 17-9
23 Wolverine State 17-10
24 Wolverine Federal 19-2
25 Wolverine Federal 20-2
26 Wolverine State 20-3
27 Wolverine Federal 20-4
28 Wolverine Federal 17-15
29 Wolverine Federal 17-16
30 Wolverine Federal 18-2
31 Wolverine State 20-5
32 Wolverine Federal 18-3
33 Wolverine Federal 19-3
34 Wolverine Federal 19-4
35 Wolverine Federal 19-5
36 Wolverine Federal 19-6
37 Wolverine Federal 18-4
38 Tank 101 (Produced Oil)
39 Tank 102 (Produced Oil)
40 Tank 103 (Produced Water)
41 Tank 301 (Bad Oil)
42 Tank 302 (Bad oil)
lnspectors Name:
lnstrument Used:
Next lnspection Due:
Cause of Leak
Tony E. Cook
Opgal EyeCGas
February-24
Repair order #Date lnspected Leak Found
Yes No
s/s/23
els/23
sls/23
sls/23
slsl23
els123
s/s123
e/s/23
els/23
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els/23
els/23
s/s123
els/23
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sls/23
elsl23
s/s/23
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elsl23
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e/6/23
e/6/23
sl6/23
e/6123
Repair Order
Description of the item to be repaired:
T-102 emergenry relief
Describe what caused the failure:
Build up of iron sulfides on the sealing surface
Were new parts used in the repair? lf so what new parts were installed?
lnstalled new viton gasket and cleaned the sealing surface
Earlxfr Tcllrrraae
Repair Order f
8ltol23
Copies of this report are located at:
WGO O.\Cnrnnrare Sharer{\Fiald nnerrtinnc\? 1? 1
Repaired by:Date of Repair:
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i wor.wBrNE oIL AND cAS
COMPANY OF UTAH, LLC
55 CAMPAU NW
GRAND RAPDS, MICHIGAN
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9590 9402 7931 2305 6401 25
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TONY COOK
WOLVERINE OIL AND GAS
COMPANY OF UTAH,LLC
55 CAMPAU NW
GRAND RAPIDS, MICHIGAN 49503