HomeMy WebLinkAboutDAQ-2024-0114131
DAQC-PBR047200001-24
Site ID 4720 (B1)
MEMORANDUM
TO: FILE – FINLEY RESOURCES, INC. – Bastian 3-8A1
THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager
FROM: Fred Goodrich, Environmental Scientist
DATE: October 28, 2024
SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION
INSPECTION DATE: August 28, 2024
SOURCE LOCATION: Lat:40.40767, Long: -110.01974
Business Office:
Finley Resources, Inc.
1308 Lake Street
Fort Worth, TX 76102
SOURCE TYPE: Tank Battery
Duchesne County
API: 4301331181
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 OOOO.
SOURCE EVALUATION: Site Type: PBR – Uncontrolled
Site powered by Line. The source registered: 12801 Estimated
Oil BBL.
, -
2
DOGM current 12 month rolling production is: 7,471 BBL's.
Utah Statute R307-506 requires a source with throughput
greater than 8,000 BBLs to have controls.
REGISTERED EQUIPMENT: Engine - Electric, Pneumatic, Tank
Visible Emissions
Visible emissions are within the following opacity limits: VOC Control Devices and Gasoline engines
0%, Diesel engines 20%, Natural Gas Engines and Boilers, Treater burners & Tank burners 10%, Mobile
source dust 10%. [R307-201-3]
In Compliance. No visible emissions were detected.
All natural gas-driven pneumatic controllers are in compliance with 40CFR 60.5390 or 60.5390a as
applicable. Tagging and record keeping requirements are not required. [R307-502-4]
In Compliance. All controllers are functioning as designed, without any issues.
Pneumatic Controllers
Truck loading is done by bottom filling or submerged fill pipe [R307-504(1)]
In Compliance. The truck loading valves were built and designed for submerged loading.
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.
Upon modification, the well site was re-evaluated against the thresholds of R307-506-4(2).
[R307-506-4(6)]
In Compliance. The DAQ did not identify any modifications or unauthorized equipment.
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.
Oil and Gas Industry Registration Requirement
The source is registered with the DAQ. [R307-505-3(3)]
In Compliance.
3
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.
Records for each of the following are kept for three years:
Monthly storage vessel vent system inspections (openings, thief hatches, pressure relief devices,
bypasses, etc.), if controlled.
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. [R307-506-5]
In Compliance. The recordkeeping procedures of the operator are found to be orderly and
complete. These records were reviewed at the local office.
NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production,
Transmission and Distribution [40 CFR 60 Subpart OOOO]
In Compliance. Source met these requirements.
PREVIOUS ENFORCEMENT
ACTIONS: In May of 2022, Inspector found leaking Thief Hatch. Due to
source being uncontrolled and Finley’s quick response of
repairs, no further action was taken.
COMPLIANCE STATUS &
RECOMMENDATIONS: In Compliance. This source was found to be clean and well-kept
with no visible or fugitive emissions. The source was inspected
by AVO and with an OGI camera and found to be free of leaks.
RECOMMENDATION FOR
NEXT INSPECTION: The DAQ has no recommendations for the next inspector other
than what are customary.
RECOMMENDATIONS FOR NSR: None.
ATTACHMENTS: None.