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HomeMy WebLinkAboutDAQ-2024-0117131 DAQC-PBR157680001-24 Site ID 15768 (B1) MEMORANDUM TO: FILE – FINLEY RESOURCES, INC. – Bar "F" 25 3A-4-2 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Fred Goodrich, Environmental Scientist DATE: September 30, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: August 7, 2024 SOURCE LOCATION: Lat:40.11247, Long: -109.718821 Business Office: Finley Resources, Inc. 1308 Lake Street Fort Worth, TX 76102 SOURCE TYPE: Tank Battery Uintah County API: 4304754331 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. , - 2 DOGM current 12 month rolling production is: 4,512 BBL's.. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Pneumatic Controllers Continuous bleed natural gas-driven pneumatic controllers are in compliance with 40 CFR 60.5390 or 60.5390a as applicable. Exemptions to tagging and record keeping requirements apply to controllers existing before 12/1/2015. [R307-502-4] In Compliance. This source does not use continuous bleed controllers as described in 40 CFR 60.5365(d)(1). Truck loading is done by bottom filling or submerged fill pipe [R307-504(1)] In Compliance. The truck loading valves are designed for submerged loading and it is routine for truck drivers to load this way. 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. 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. Records for each of the following are kept for three years: Storage vessel vent system inspections (openings, thief hatches, pressure relief devices, bypasses, etc.), if required 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 per R307-506-4(2)[R307-506-5] In Compliance. Records Observed. 3 Natural Gas Engines Engines subject to R307-510 (does not have an AO, began operations, installed or modified after January 1, 2016) meet the following limits: Maximum Engine hp Emission Standards in (g/hp-hr) NOx CO VOC HC+NOx >25 hp and < 100 hp - 4.85 - 2.83 >100 hp 1.0 2.0 0.7 - [R307-510-4(1)] In Compliance. Operator appears to meet R307-510-4(1). Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)] In Compliance. Operator’s initial performance tests meet the criteria. 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 stack vents vertically and meets requirements. Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. The stack testing report was presented to the DAQ at the records review. Visible Emissions Visible emissions, except for unavoidable irregularities that do not exceed three minutes, are within the following opacity limits: Installations constructed on or before 4/25/1971 40% Installations constructed after 4/25/1971 20% Gasoline engines 0% Diesel engines manufactured after 1/1/1973 20% Diesel engines manufactured before 1/1/1973 40% Note: Required VOC control devices shall have no visible emissions per R307-508-3. [R307-201-3] In Compliance. No visible emissions were detected. 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. 4 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. NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution [40 CFR 60 Subpart OOOO] In Compliance. Observed. PREVIOUS ENFORCEMENT ACTIONS: None in the past 5 years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to the site, the overall status is: In Compliance. RECOMMENDATION FOR NEXT INSPECTION: The DAQ has no recommendations for the next inspector other than what are customary. RECOMMENDATIONS FOR NSR: None. ATTACHMENTS: None.