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Home My WebLink AboutDAQ-2024-0117221 DAQC-PBR084040002-24 Site ID 8404 (B1) MEMORANDUM TO: FILE – FINLEY RESOURCES, INC. – Roosevelt Unit 4-19 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Fred Goodrich, Environmental Scientist DATE: August 27, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: July 25, 2024 SOURCE LOCATION: Lat:40.38097, Long: -109.920978 Business Office: Finley Resources, Inc. 1308 Lake Street Fort Worth, TX 76102 SOURCE TYPE: Tank Battery Uintah County API: 4304736599 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. SOURCE EVALUATION: Site Type: PBR – Uncontrolled Voluntarily Controlled by Flare, Site powered by Engine. The source registered: 7249 Estimated Oil BBL. , - 2 DOGM current 12 month rolling production is: 5,237 BBBLs. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Pneumatic, Tank VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] In Compliance. The operator has the minimum components installed and they appear to not be leaking. 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. Snap acting valves are in use here. 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 Truck loading is done by bottom filling or submerged fill pipe. [R307-504(1)] In Compliance. Tanks are plumbed for submerged loading. Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. None were found open upon arrival. Upon modification, the well site was re-evaluated against the thresholds of R307-506-4(2). [R307-506-4(6)] In Compliance. This well has been sidetracked or deepened and refractured in a different formation. This source should now be evaluated using NSPS OOOOa regulations. Currently the production does not meet the 8,000 BBL threshold found in R307-506. 3 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. This source does not meet the production (or PTE) to trigger NSPS OOOOa as a tank affected facility nor R307-506. Vessel vent system inspections and the recordkeeping requirements are not required here. Natural Gas Engines Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)] In Compliance. The engine installed here is not EPA certified. It would require an initial performance test but the retention time for that testing report has lapsed and was not presented to the DAQ. 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. Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. The engines at this source were installed prior to 2016 and are not subject to this regulation. 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 noticed. 4 Emission Inventory: An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. The operator submitted to the 2020 inventory. Applicable Federal Regulations: 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. In Compliance. This source does not have the production to meet the PTE for a tank affected facility. There are no other affected facilities installed. NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. In Compliance. The engine is not certified compliant with this subpart and requires an initial performance test, maintenance plan, and records of the maintenance conducted. The retention time of the performance test has expired. The records of the engine maintenance were reviewed at the operators office. PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years, but the DAQ Inspector found leaking components during the 2022 evaluation. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to the site, the overall status is: Not in Compliance - This is an uncontrolled source. The DAQ found a leaking regulator for the pilot on the emergency flare. No other components were found to be leaking. There were no visible emissions. No further enforcement action is taken. The required records were reviewed at the local office. RECOMMENDATION FOR NEXT INSPECTION: The DAQ has no recommendations for the next inspector other than what are customary. The DAQ recommends the inspection frequency of this source be reduced. RECOMMENDATIONS FOR NSR: None. ATTACHMENTS: None.