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Home My WebLink AboutDAQ-2024-010855State SPENCER J. COX Govenror DEIDRE HENDERSON Lieutenanl Goventor Department of Environmental Quality Kimberly D. Shelley Executive Direclor DTVISION OF AIR QUALIry Bryce C. Bird Direclor September 17,2024 DAQC-898-24 Site ID's : 1 0023 5, 1 0023 6, 100237, 1 0023 8, 100239, 100240, 100241, t00242, 100243, 100244, 100245, 1 00246, 100247, 100248, 100249, 1 00250, 1 0025 l, t00252, 100253, 100254, 100255, 100256, 100257, 100258, 100259, I 00260, t00261, 100262, 100263, 100264 (Bl) Sent Via Certified Mail No. 70190700000208347358 Franklin Ihekwoaba Winds Exploration & Production, LLC 12818 Secret Forest Court Cypress, Texas 77 429-8309 Sent Via Certified Mail No. 70190700000208347365 Michael Collett Registered Agent Winds Exploration & Production, LLC 4778 North 300 West, Suite 200 Provo, Utah84604-7710 Re: Notice of Violation and Order to Comply - Winds Exploration & Production, LLC - Utah Administrative Code R307-505-3, R307-501(l)(a), and R307-501(l)(c) - Carbon County and Duchesne County Dear Mr. Ihekwoaba and Mr. Collett: Winds Exploration & Production, LLC is required to update registration information with the Utah Division of Air Quality (DAQ) within 30 days of changes to a company name for new and existing operations at a source with Standard Industrial Classification codes in the major group 13, which includes but is not limited to industries involved in oil and natural gas exploration, production, and transmission operations, well production facilities, natural gas compressor stations, natural gas processing plants and commercial oil and gas disposal wells, and evaporation ponds, as stated in Utah Administrative Code (UAC) R307-505. 195 No$h 1950 West. Salt Lake City, UT Mailing Address: P.O. Box 144820 . Salt Lake City, UT 841144820 Telephone (801) 5364000. Fax (801) 5364099. T.D.D. (801) 903-3978 ww.deq.utuh.gov Printed on I00% recycled paper DAQC-898-24 Page 2 On May 13,2024, a representative of the DAQ conducted inspections of Winds Exploration & Production, LLC's Castlegate Field gas wells located in Carbon County, Utah. The DAQ inspected twenty gas wells and of those twenty wells, there were five significant volatile organic compounds (VOC) leaks; Castlegate Fed 22C-9-12-10, Jensen 42C-9-12-10, Jensen 1l-10-12-10, Jensen 23C-9-12-10, and Jensen 2-8-12-10 are the gas wells showing significant VOC leaks. The optical gas imaging of these VOC leaks can be viewed at the following link: https://drive.google.com/drive/folders/l Q4RtODBoH_doyDXPmHn6r_i4olkvSXWx?usp:sharing The five gas wells significantly leaking VOC, which was25%o of gas wells inspected, shows the sources have not been operated and maintained so as to minimize emission of VOC to the atmosphere to the extent reasonably practicable, and is in violation of UAC R307-501. The associated gas (VOC) venting from the wellhead at Castlegate Fed 22C-9-12-10 is in violation of UAC R307-5 I l, which states that associated gas from a completed well shall either be routed to a process unit for combustion, routed to a sales pipeline, or routed to an operating VOC control device except for emergency release situations as defined in Section R307-511-2. The enclosed Notice of Violation and Order to Comply is based on the findings documented by the DAQ. The Order is effective on the date of issuance, which is the date it was signed and dated. Compliance with the Order is mandatory and will not relieve the company of liability for any past violations. To request a formal administrative hearing, the procedures detailed in the paragraph entitled "Compliance, Opportunity for a Hearing" must be followed. The Order requires Winds Exploration & Production, LLC to submit written notification of its intent to comply, outlining how, and when compliance will be achieved to the DAQ in writing on or before the l5th day after receipt of this Order. Questions regarding this matter may be directed to Rik Ombach at (801) 536-4164 or rombach@utah.gov. When responding, refer to the DAQC number in the upper right corner of this letter. Sincerely, 4-d Bryce C. Bird Director BCB:KG:rh Enclosure: Notice of Violation and Order to Comply cc: Kimberly D. Shelley, Executive Director, Department of Environmental Quality Southeast Utah Health Department DAQC-898-24 Page 3 The Utah Division of Air Quality ooOoo ln the Matter of : Notice of Violation Winds Exploration & : and Order to Comply Production, LLC: : : No.20240905007 ooOoo This Notice of Violation and Order to Comply is issued by the Director of the Utah Division of Air Quality (DAO) pursuant to the Utah Air Conservation Act (Act), Utah Code Ann. $ 19-2-101 et seg.. The Director is authorized to issue Notices of Violation pursuant to Utah Code Ann. S 19-2- 110. The Director has the authority to issue orders in accordance with Utah Code Ann. $$ 19-2- 107(2XaXxiii) and 19-2-11 0(1 ). Findings: 1. Winds Exploration & Production, LLC operates twenty-nine natural gas wells located in the Castlegate Field in Carbon County, Utah and one disposalwell located in Duchesne County, Utah. 2. Winds Exploration & Production, LLC is required to comply with Utah Administrative Code (uAc) R307-505. 3. UAC R307-505-3 states: (3)An owner or operator shall update the registration information within 30 days of any of the following: (a) changes to company name, (b) removal or addition of control devices, or (c) termination of operations. (4) Registration shall be completed online in a format provided by the Division and shall include the following general information: company name, mailing address, source location, source manager or point of contact, process description, capacity and quantity of emitting equipment on-site, fueltype of combustion related equipment (i.e. diesel, natural gas, propane, orfield gas), emissions control devices installed, emissions and certification that the facility is in compliance with R307-506 through R307-510. DAQC-8e8-24 Page 4 4. Winds Exploration & Production, LLC is required to comply with UAC R307-501 5. On May 13,2024, a representative of the DAQ conducted inspections of Winds Exploration & Production, LLC's Castlegate Field gas wells located in Carbon County, Utah. The DAQ inspected twenty gas wells and of those twenty wells, there were five significant volatile organic compounds (VOC) leaks; Castlegate Fed 22C-9-12-10, Jensen 42C-9-12-10, Jensen 11-10-12-10, Jensen 23C-9-12-10, and Jensen 2-8-12-10 are the gas wells showing significant VOC leaks. The optical gas imaging of these VOC leaks can be viewed at the following link: https://drive.google.com/drive/folders/l Q4RtODBoH_doyDXPmHn6l4olkvSXWx?usp=s haring The five gas wells significantly leaking VOC, which was 25o/o of gas wells inspected, shows the sources have not been operated and maintained so as to minimize emission of VOC to the atmosphere to the extent reasonably practicable and is in violation of UAC R307-501 -4(1 )(a) and R307-501 -4(1 Xc). UAC R307-5014(1 )(a) states: All crude oil, condensate, and intermediate hydrocarbon liquids collection, storage, processing and handling operations, regardless of size, shall be designed, operated and maintained so as to minimize emission of volatile organic compounds to the atmosphere to the extent reasonably practicable. UAC R307-501-4(1)(c) states: Determination of whether or not 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, infrared camera images, opacity observations, review of operating and maintenance procedures, and inspection of the source. On May 29,2024, DAQ issued a Compliance Advisory (DAOC-S13-24) regarding the violations of UAC R307-501-4(1)(a) and R307-501-4(t Xc). Winds Exploration & Production, LLC never responded to the Compliance Advisory despite DAQ's steady attempts of communication through mail, email, and phone. 6. 7. L 9. Winds Exploration & Production, LLC is required to comply with UAC R307-511. DAQC-898-24 Page 5 10. UAC R307-511-4 states: Associated gas from a completed well shall either be routed to a process unit for combustion, routed to a sales pipeline, or routed to an operating VOC control device except for emergency release situations as defined in Section R307-511-2. Violation(s): Based on the foregoing Findings and in accordance with Utah Administrative Code, Winds Exploration & Production, LLC is in violation of: 1. Utah Administrative Code R307-505 for failure to update the registration information for new and existing operations at a source with Standard lndustrial Classification codes in the major group 13, which includes but is not limited to industries involved in oil and natural gas exploration, production, and transmission operations, well production facilities, natural gas compressor stations, natural gas processing plants and commercial oil and gas disposal wells, and evaporation ponds, within 30 days of changes to company name, removal or addition of control devices, or termination of operations. 2. Utah Administrative Code R307-501 for failure to operate and maintain sources so as to minimize emission of volatile organic compounds to the atmosphere to an extent reasonably practicable. 3. Utah Administrative Code R307-511 for failure to route associated gas venting from the wellhead Castlegate Fed 22C-9-12-10 to a sales pipeline. Order: Based on the foregoing Findings and Violations, and pursuant to Utah Code Ann. SS 19-2- 107(2)(a)(xiii), 19-2-110(1), and 19-2-120, Winds Exploration & Production, LLC is hereby ordered to: 1. lmmediately initiate all actions necessary to achieve total compliance with all applicable provisions of the Act, the rules promulgated under the Act, and the permit if applicable. DAQC-898-24 Page 6 2. Notify this office in writing on or before the fifteenth (1sth) day after receipt of this letter of Winds Exploration & Production, LLC's intent to comply with this Order and indicate how compliance is to be achieved. Compliance, Opportunity for a Hearing: This Order is effective on the date of issuance, which is the date it is signed and dated. Pursuant to Utah Code Ann.$ 19-1-301 and UAC R305-7- 3, you have thirty (30) days after issuance of this Notice of Violation and Order to Comply to seek a review of the same by filing a written request for agency action with the Utah Department of Environmental Quality. lf a proper request, compliant with all applicable laws, is not made within the time permitted, the Notice of Violation and Order to Comply shall be a final agency action and may be enforced in further adjudicative proceedings. Civil Penalty: You are in violation of Utah Administrative Code, and consequently, the Utah Air Conservation Act, state rules promulgated under the Act, and the applicable federal rules. As such, you are subject in a civil proceeding to a penalty not to exceed $10,000 per day for each violation. The statutory penalty amount may be determined and satisfied by agreement between Winds Exploration & Production, LLC's and DAQ. Thirty (30) days after the issuance of this Notice of Violation and Order to Comply, and if no request for agency action is filed, DAQ may elect to have the amount of the penalty assessed and imposed by filing a civil action against you in a court of proper jurisdiction and venue. p6[gd tottr day of September 2024. 4-rd Bryce C. Bird, Director Utah Division of Air Quality ililtilIllilffiHmffiTfffimT j=ll Il t SPSTRACN(ITIG#Flnt-GNass Ma[ Pootrge & Fee Pald USP€ Pffinltilo. G-l0 c fr =zg 5rt * (F I t-CJo $-Elll!. bAro.c- 918-z+ ,l,lilllrtrhrl,llrr,rf plilf rrf ,nf rttrltf ,,l,,,f ,rf t;r,f AH DIVISION OF AIR QUALITY .QOMPLIANCE SECTION::f,o gox444820 sALr LAKE CITY UT 841144E20 I Complete items 1,2, and 3.r Print your na.me and addrcss on the roverse so that we can return the card to you.r Attach this card to the back ol the mailpiece, or on the tont lf -L jggrgjggg$t":D. ls d€lh/ery addrsss difi€rent fiom item 1? -YES, enterdelivery addr€ss below: E Agent Addrcsse6 ol1-3 Y6s ENo ERANKLINIHEKWOABA wiNps DGLoRATIoN &' pRffDirc rlo N. LLC rzer8 sEiREr FoREsieOfE[ - .CYPRESS. TX 7 7 429 -8309 _Illr[mmmmml ll ll [ il[ lt lt lll ]t 9590 9402 8888 4064 116572 2. Articlo Number _rico Type E Adultslsnaturotr Adult Slgnature Be3trictod t elh,6ry M6ll@ tr H{orltyMallE(prE@E Regl3tGrad Mallntr Reglster€d Ma[ BesfrlctodDeliverytr Slgnatulcontrrnauooil El SignaturuConffrmdlon REstricted Dollvery Domestlc Retum R€c€lpt 7El,t u?80 uE0e E63r{ 7350 E lnEul€d Mall RBtrlctod Dsfivgty I PS Form 38:1.1; luty ZOZ0 PSN 753G02-oo0-9053 tr C6.tifl6d Mall ResB'lctod t olhrsrytr Collecton Delfuery tr Collsct on Dellvery Restlcted Dolvarytr lnsuI€d Mall FRANKLIN IHEKWOABA WTNDS E)GLORATION & PRODUCTION, LLC _ I28I8 SECRET FOREST COURT EO |.r|mr! Jm6trt ruEItrltrt EErrEI trrlErr CYPRESS, TX 77429.8309 Tracting Number 701907000002083 47365 Copy Add to lnformed Delivery Delivered Delivercd, PO Box SALT LAKE Ctil UT 84114 September 23, 2024, 9:26 am Available for Pickup SALT LAKE CITY 1760 W 2100 S SALT LAKE CITY UT 84199-9998 M-F 0500-1800; SAT 1000-1400 September 21, 2024, 7 :04 am Anived at Post ffice SALTLAKECITY, UT84199 September 21, 2024, 4:54 am Anived at USPS Regional Facility SALT LAKE CITY UT DISTRIBUTION CENTER September ?0,2024, 12:29 9m Fonruard Expired PROVO, UT 84604 September 19, 2024, 9:1 2 am Anived at USPS Regional Facility PROVO UT PROCESSING CENTER September 18, 2024, 3:1 5 pm Departed USPS Regional Facill$ SALT LAKE CITY UT DISTRIBUTION CENTER September 18, 2024, 1 :07 am Anived at USPS Regional Facility SALT LAKE CITY UT DISTRIBUTION CENTER September 17, 2024, 10:41 pm Latest Update Your ttem has been clellvered and ls avallaUe at a PO Box at 9:26 am on September23,z0z4 in SALT !.Al(E CITY, UT U114. Get More Out of USPS Tracklng: USPS Tracking Ptus@ I,, -.0mr! Jm COtrt ruEEIEI trtEr\-E rr{Er! MICHAEL COLLETT REGISTEREDAGENT WINDS DOLORATION & PRODUCTION, LLC 4778 N 300 W STE 200 PROVO,UT 84604-7710 y\,rsleu d\/ t1 f ?+ Posttnad( HoI€ DAOc- Sq(-z) ocl 1 1 2024 DIVISION OFAIR QUALITY trndrmn €bt0d@o, t- EnrtrmacocUOrarc'lol !- Ec.dfi.dMJF.&lct dmwv t- trAditslednnrgt.frd t- EAaui stgrl.tn rl.dctcd Ddriry 8 -