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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.