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Home My WebLink AboutDAQ-2024-0115111 DAQC-PBR047090001-24 Site ID 4709 (B1) MEMORANDUM TO: FILE – FINLEY RESOURCES, INC. – Gardner 36-16A-3-2 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Manager FROM: Fred Goodrich, Environmental Scientist DATE: November 8, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: August 7, 2024 SOURCE LOCATION: Lat: 40.17517 Long: -109.71453 Business Office: Finley Resources Inc. 1308 Lake Street Fort Worth, TX 76102 SOURCE TYPE: Tank Battery Uintah API: 4304754486, 4304754711 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, 40 CFR 60 Subpart OOOO. SOURCE EVALUATION: Site Type: PBR-Uncontrolled Controlled by flare, site powered by engine. The source registered: 7,750 Estimated Oil BBL. , - 2 DOGM current 12 month rolling production is: 1,885 BBL's. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Engine - Engine - Natural Gas 2-Stroke Lean Burn Make - Ajax Model - E-565 Mfg Year - 2014 Horse Power - 40 Combustion - Natural Gas, 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. VOC emissions are, at all times, minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] In Compliance. Control equipment appeared to be correctly designed and engineered to meet this criteria. Pneumatic Controllers 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 functioning as designed, without any issues. Storage Vessels 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. 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. Air pollution control equipment is installed appropriately, maintained and operated, pursuant to the manufacturers specifications, to control emissions. [R307-501-4(2)] In Compliance. Tank emissions are routed to an enclosed combustor. Natural Gas Engines 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. The engine exhaust vents were found properly installed vertical. 3 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. 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. Engines subject to R307-510 shall be certified or have an initial performance test per CFR 60.4244. [R307-510-4(2)] In Compliance. Stack testing appeared to be completed and emissions were within the limits established by NSPS (60) JJJJ. Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. Operators initial performance tests meet the criteria. Engines that were installed, relocated or modified after January 1, 2016 are required to show compliance with Table 1 of R307-510-4 through a performance test evaluation that is reviewed by the DAQ and found to be in compliance. [R307-510-4(1)] In Compliance. Operator appears to meet R307-510-4(1). 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 appeared to be orderly and complete. 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. 4 NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution [40 CFR 60 Subpart OOOO] In Compliance. This source is permitted with the State of Utah with legal and enforceable limits, They do not have the production that would qualify under 40 CFR (60) OOOO for a tank affected facility. 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. Appears to DAQ source to meet these standards. PREVIOUS ENFORCEMENT ACTIONS: August of 2022, inspector found operator LDAR program had exceeded the 15 day repair limit on some items. Due to source being under the 8,000 BBL threshold and with cooperation from operator, no further action took place. 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.