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HomeMy WebLinkAboutDAQ-2024-0109751 DAQC-CI156680002-24 Site ID 15668 (B1) MEMORANDUM TO: FILE – WATER DISPOSAL, INC. – Produced Water Disposal Facility THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Stephen Foulger, Environmental Scientist DATE: September 17, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Duchesne County INSPECTION DATE: August 23, 2024 SOURCE LOCATION: Located 0.6 miles along North Crescent Road from intersection of 2000 West and North Crescent Road Duchesne County, UT 84066 DIRECTIONS: Lat: 40.353843, Lon: -110.0217 SOURCE CONTACTS: Doug Betts, Local Contact Phone: (435) 724-1165, Email: karldouglasbetts@yahoo.com OPERATING STATUS: Operating PROCESS DESCRIPTION: Water Disposal, Inc. (WDI) owns and operates a produced water treatment facility located approximately 4 miles northwest of Roosevelt in Duchesne County. Produced water is received by truck from oil and gas operations and pumped into any of the produced water storage tanks. The produced water undergoes phase separation using various decanting tanks and centrifuges for the recovery of oil and condensates. The decanted water is routed to pre-injection tanks and pumped into the injection well on site. The oil separated from the produced water decanting process is pumped to heated mixing tanks, where the oil is mixed with coagulant and demulsifying agents. After a period of mixing, the solids and water that still remain in the oil are removed by a centrifuge. The oil is piped to heated oil storage tanks for transportation off site. Water from the centrifuging process is pumped back to the decanting tanks, and the centrifuged solids are stored in a covered and sealed containers before being transported and disposed of offsite. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN156680002-24, dated August 13, 2024 2 SOURCE EVALUATION: Name of Permittee: Permitted Location: Water Disposal, Inc. Produced Water Disposal Facility 2285 Lucky John Drive Located 0.6 miles along North Crescent Road from intersection of 2000 West and North Crescent Road Park City, UT 84060-6914 Duchesne County, UT 84066 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] Status: In Compliance. I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] Status: In Compliance. No limits set in the AO were found exceeded at the time of inspection. 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] Status: In Compliance. All modifications were addressed in an approved AO. 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] Status: In Compliance. Records required to be kept by the AO were requested and were observed at the time of inspection. 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] Status: In Compliance. Good pollution and emissions reduction practices found employed at the time of inspection. 3 I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] Status: In Compliance. No breakdowns were reported at the time of inspection. I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. Source was reported in the most recent emission inventory. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of only equipment permitted found in current AO: Status: In Compliance. Only permitted equipment was found onsite at the time of inspection. II.B Requirements and Limitations II.B.1 Source-Wide Requirements II.B.1.a 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% opacity. [R307-401-8] Status: In Compliance. No visible emissions were observed at the time of inspection. II.B.1.a.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. [R307-401-8] Status: In Compliance. Opacity observation records were reviewed at the time of inspection and found to be compliant. II.B.2 Tank Requirements II.B.2.a The owner/operator shall not produce more than 30,000 barrels (1 barrel = 42 gallons) of crude oil per rolling 12-month period. [R307-401-8] Status: In Compliance. These records were reviewed at the time of inspection and showed proper production levels. II.B.2.a.1 The owner/operator shall: A. Determine production with sales receipts B. Record production on a monthly basis C. Use the production data to calculate a new rolling 12-month total by the 25th day of each month using data from the previous 12 months D. Keep the production records for all periods the plant is in operation 4 [R307-401-8] Status: In Compliance. Source has a new AO and has been instructed on coming into compliance with these conditions. II.B.2.b The owner/operator shall store all centrifuge solids and tank sludge in an enclosed storage vessel prior to the centrifuge solids and tank sludge being hauled off site. [R307-401-8] Status: In Compliance. Centrifuge solids and tank sludge found properly stored at the time of inspection. II.B.2.c The owner/operator shall contain all centrifuge solids and tank sludge in the enclosed storage vessel immediately after any centrifuge solids and tank sludge is produced. The owner/operator shall have no standing centrifuge solids or tank sludge present outside the enclosed storage vessel on site at any time. [R307-401-8] Status: Out of Compliance. Source has a new AO and has been instructed on coming into compliance with these conditions. II.B.2.d The owner/operator shall load all storage tanks and tanker trucks on site by the use of bottom filling or a submerged fill pipe. [R307-401-8] Status: In Compliance. Truck loading found properly set up at the time of inspection. II.B.2.e The owner/operator shall keep the storage tank thief hatches and other tank openings closed and sealed except during tank unloading or other maintenance activities. [R307-401-8] Status: In Compliance. Thief hatches found closed and latched at the time of inspection. 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. [R307-401-8] Status: In Compliance. Source has a new AO and has been instructed on coming into compliance with these conditions. II.B.2.f.1 Records of thief hatch inspections shall include the date of the inspection and the status of the thief hatches. [R307-401-8] Status: In Compliance. Source has a new AO and has been instructed on coming into compliance with these conditions. II.B.3 Combustor Requirements II.B.3.a The owner/operator shall route all exhaust gas and/or vapors from all storage tanks and the sealed solids storage to the operating combustor. [R307-401-8] Status: Out of Compliance. Source has a new AO and has been instructed on coming into compliance with these conditions. 5 II.B.3.b The combustor shall operate with a continuous pilot flame and be equipped with an auto-igniter. [R307-401-8] Status: In Compliance. Continuous pilot flame and operational auto-ignitor found in proper working order at the time of inspection. II.B.3.c The owner or operator shall maintain records demonstrating the date of installation and manufacturer specifications for the auto-igniter required under R307-503-4. [R307-503-4] II.B.3.d The combustor shall operate with no visible emissions. [R307-401-8] Status: In Compliance. No visible emissions were observed at the time of inspection. II.B.3.d.1 Opacity observations of emissions from the combustor shall be conducted according to 40 CFR 60, Appendix A, Method 22. [R307-401-8] Status: In Compliance. Source has a new AO and has been instructed on coming into compliance with these conditions. II.B.3.e The owner/operator shall install a combustor that is certified to meet a VOC control efficiency of no less than 98%. [R307-401-8] Status: In Compliance. Certified combustor found installed at the time of inspection. II.B.3.e.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's emissions guarantee for the installed combustor. [R307-401-8] Status: In Compliance. Source has a new AO and has been instructed on coming into compliance with these conditions. II.B.4 Haul Road Requirements II.B.4.a The owner/operator shall comply with all applicable requirements of UAC Rule R307-205 for Fugitive Emission and Fugitive Dust sources on site. [R307-205] Status: In Compliance. Source has a new AO and has been instructed on coming into compliance with these conditions. II.B.4.b The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources on site to exceed 20% opacity. [R307-401-8] Status: In Compliance. No visible emissions were observed at the time of inspection. II.B.4.b.1 Opacity observations of fugitive dust from intermittent sources shall be conducted according to 40 CFR 60, Appendix A, Method 9; however, the requirement for observations to be made at 15- second intervals over a six-minute period shall not apply. The number of observations and the time period shall be determined by the length of the intermittent source. For fugitive dust generated by mobile sources, visible emissions shall be measured at the densest point of the plume but at a point not less than one-half vehicle length behind the vehicle and not less than one-half the height of the vehicle. [R307-401-8] Status: In Compliance. Source has a new AO and has been instructed on coming into compliance with these conditions. 6 II.B.4.c The owner/operator shall cover all unpaved haul roads and wheeled-vehicle operational areas with road base material. The owner/operator shall use water application to maintain opacity limits listed in this AO. If the temperature is below freezing, the owner/operator may stop applying water to the unpaved haul roads and wheeled-vehicle operational areas. The owner/operator shall resume applying water to the unpaved haul roads and wheeled-vehicle operational areas when the temperature is above freezing. [R307-401-8] Status: In Compliance. Roads found properly watered and made of proper material at the time of inspection. II.B.4.c.1 Records of water application shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date and time treatments were made B. Number of treatments made and quantity of water applied C. Records of temperature, if the temperature is below freezing [R307-401-8] Status: In Compliance. Water records were observed and found to be compliant at the time of inspection. II.B.4.d The owner/ operator shall not exceed 2,112 feet (0.4 miles) of unpaved haul roads on site. [R307-401-8] Status: In Compliance. Source has a new AO and has been instructed on coming into compliance with these conditions. II.B.4.d.1 The unpaved road length shall be determined through source records or GPS measurements. [R307-401-8] Status: In Compliance. Source has a new AO and has been instructed on coming into compliance with these conditions. II.B.5 Monitoring Requirements of Fugitive Emissions (Leak Detection and Repair) II.B.5.a The owner/operator shall develop a fugitive emissions monitoring plan. At a minimum, the plan shall include: A. Monitoring frequency B. Monitoring technique and equipment C. Procedures and timeframes for identifying and repairing leaks D. Recordkeeping practices E. Calibration and maintenance procedures 7 [R307-401-8] Status: In Compliance. Source has a new AO and has been instructed on coming into compliance with these conditions. II.B.5.a.1 The plan shall address monitoring for "difficult-to-monitor" and "unsafe-to-monitor" components. [R307-401-8] Status: In Compliance. Source has a new AO and has been instructed on coming into compliance with these conditions. II.B.5.b The owner/operator shall conduct monitoring surveys on site to observe each "fugitive emissions component" for "fugitive emissions." A. "Fugitive emissions component" means any component that has the potential to emit fugitive emissions of VOC, including but not limited to valves, connectors, pressure relief devices, open-ended lines, flanges, covers and closed vent systems, thief hatches or other openings, compressors, instruments, and meters. B. "Fugitive emissions" are considered any visible emissions observed using optical gas imaging or a Method 21 instrument reading of 500 ppm or greater. [R307-401-8] Status: In Compliance. Source has a new AO and has been instructed on coming into compliance with these conditions. II.B.5.b.1 Monitoring surveys shall be conducted according to the following schedule: A. No later than 90 days after the issuance date of this Approval Order B. Semiannually after the initial monitoring survey. Consecutive semiannual monitoring surveys shall be conducted at least 4 months apart. C. Annually after the initial monitoring survey for "difficult-to-monitor" components. D. As required by the owner/operator's monitoring plan for "unsafe-to-monitor" components. [R307-401-8] Status: In Compliance. Source has a new AO and has been instructed on coming into compliance with these conditions. II.B.5.b.2 Monitoring surveys shall be conducted using one or both of the following to detect fugitive emissions: A. Optical gas imaging (OGI) equipment. OGI equipment shall be capable of imaging gases in the spectral range for the compound of highest concentration in the potential fugitive emissions. 8 B. Monitoring equipment that meets U.S. EPA Method 21, 40 CFR Part 60, Appendix A. [R307-401-8] Status: In Compliance. Source has a new AO and has been instructed on coming into compliance with these conditions. II.B.5.c If fugitive emissions are detected at any time, the owner/operator shall repair the fugitive emissions component as soon as possible but no later than 15 calendar days after detection. [R307-401-8] Status: In Compliance. Source has a new AO and has been instructed on coming into compliance with these conditions. II.B.5.c.1 The owner/operator shall resurvey the repaired or replaced fugitive emissions component no later than 30 calendar days after the fugitive emissions component was repaired.[R307-401-8] Status: In Compliance. Source has a new AO and has been instructed on coming into compliance with these conditions. II.B.5.d The owner/operator shall maintain records of the fugitive emissions monitoring plan, monitoring surveys, repairs, and resurveys. [R307-401-8] Status: In Compliance. Source has a new AO and has been instructed on coming into compliance with these conditions. Section III: APPLICABLE FEDERAL REQUIREMENTS In addition to the requirements of this AO, all applicable provisions of the following federal programs have been found to apply to this installation. This AO in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including UAC R307. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: EMISSION INVENTORY: The emissions listed below are an estimate of the total potential emissions (PTE) from Water Disposal, Inc. – Produced Water Disposal Facility on the Approval Order (AO) DAQE-AN156680002-24, dated August 13, 2024. PTE are supplied for supplemental purposes only. Status: In Compliance. Source was reported in the most recent emission inventory. 9 PREVIOUS ENFORCEMENT ACTIONS: CA and ESA issued in 2023 for non-compliance. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN156680002-24, dated August 13, 2024, the overall status is: Out of Compliance. Source was unfamiliar with their new AO requirements and were left with instructions on coming into compliance. Overall, source was found in good working order with some improvements needed to come into compliance. RECOMMENDATION FOR NEXT INSPECTION: Recommend to increase inspection frequency. Source had just received their new AO when this inspection was performed and should be visited again to ensure they have made the needed changes to the source and started adequate record keeping practices. ATTACHMENTS: None.