The URL can be used to link to this page

Home My WebLink AboutDAQ-2024-0105451 DAQC-PBR100377001-24 Site ID 100377 (B1) MEMORANDUM TO: FILE – FINLEY RESOURCES INC. – Deep Creek 1-35-4-2E THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Manager FROM: Fred Goodrich, Environmental Scientist DATE: September 16, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: July 18, 2024 SOURCE LOCATION: Lat: 40.09789 Long: -109.7277 Business Office: Finley Resources Inc. 1308 Lake Street Fort Worth, TX 76102 SOURCE TYPE: Tank Battery Rural Uintah County API: 43047- 55929 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. Federal Subpart: 40 CFR 60 Subpart JJJJ. SOURCE EVALUATION: Site Type: PBR-Controlled Voluntarily controlled by flare, site powered by engine. The source registered: 91,250 Estimated Oil BBL. DOGM current 12 month rolling production is: 4,878 BBLs. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. , - 2 REGISTERED EQUIPMENT: Engine - Engine - Natural Gas 4-Stroke Rich Burn Make - Doosan Model - D14.6L Mfg Year - 2012 Horse Power - 449 Combustion - Natural Gas, Pneumatic, Tank VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] In Compliance. Associated gas is routed to a sales gathering line. Vessel vent lines route emissions to a combustion device. Tanks all have thief hatches and PRV's that are closed and not leaking. Pneumatic Controllers Continuous bleed natural gas-driven pneumatic controllers are in compliance with 40 CFR 60.5390 or 60.5390a as applicable. Exemptions to tagging and record keeping requirements apply to controllers existing before 12/1/2015. [R307-502-4] In Compliance. This source does not use continuous bleed natural gas-driven pneumatic controllers. Truck loading is done by bottom filling or submerged fill pipe. [R307-504(1)] In Compliance. The truck loading area is suitable for submerged loading and it is routine for truck drivers to load this way. Oil and Gas Industry Registration Requirement The source is registered with the DAQ. [R307-505-3(3)] In Compliance. 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. All hatches were found closed at the start of the evaluation. 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. Monthly production totals were provided. 3 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. Stack testing was completed and emissions were within the limits established by NSPS (60) JJJJ. See DAQC-1602-22 Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)] In Compliance. Stack testing was completed and emissions were within the limits established by NSPS (60) JJJJ. See DAQC-1602-22 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. Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. On file at DAQ 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 emissions were detected by use of the USEPA Method 9. Emission Inventory: An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. The operator submitted for the 2020 emissions inventory. The results for the 2023 inventory have not yet been released. 4 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 [40 CFR 60 Subpart OOOOa] In Compliance. The tank battery at this source no longer has the production to have the PTE in excess of 4 TPY and are no longer an affected facility under this subpart. There are no other affected facilities installed. NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines [40 CFR 60 Subpart JJJJ] In Compliance. The engines at this source have been performance tested and the emissions were within the limits allowed in this subpart. The recordkeeping and maintenance provisions are also met to maintain the certification. PREVIOUS ENFORCEMENT ACTIONS: Inspected on November 18, 2021, (DAQC-086-22) and found not in compliance. No enforcement action was taken but the inspection was forwarded to the USEPA for inclusion in the joint lawsuit. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to the site, the overall status is: In Compliance. The source was surveyed by AVO and with an OGI camera and was found to be well-kept with no visible or fugitive emissions. Requested records were provided and reviewed at the Denver office. 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 be reduced as it no longer controlled. RECOMMENDATIONS FOR NSR: None ATTACHMENTS: None