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HomeMy WebLinkAboutDAQ-2025-0020951 DAQC-PBR031850001-25 Site ID 3185 (B1) MEMORANDUM TO: FILE – FOURPOINT RESOURCES, LLC – Stewart 16-20-4-2 THROUGH: Rik Ombach, Minor Source Oil and Gas Section Manager FROM: Fred Goodrich, Environmental Scientist DATE: April 17, 2025 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: March 20, 2025 SOURCE LOCATION: Lat: -110.125122070313 Long: 40.1149787902832 Business Office: FourPoint Resources, LLC 100 Saint Paul Street, Suite 400 Denver, CO 80206 SOURCE TYPE: Tank Battery Duchesne API: 4301350298 SOURCE CONTACTS: Brad Rowser, Field Contact Phone: 435-503-5360, Email: browser@fourpointresources.com Jeanette Liang, Corporate Environmental Contact Phone: 303-248-6822, Email: jliang@fourpointenergy.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 No Flare Controls, Site powered by Engine. The source registered: 3,199 Estimated Oil BBL. , - 2 DOGM current 12 month rolling production is: 229 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-42 Mfg Year - Pre 7/1/2008 Horse Power - 40 Combustion - Natural Gas, Pneumatic 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 during evaluation. VOC emissions are, at all times, minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] In Compliance. 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. This source does not use continuous bleed controllers. 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. 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. Meets this requirement. Engines subject to R307-510 shall be certified or have an initial performance test per CFR 60.4244. [R307-510-4(2)] In Compliance. Meets this requirement. 3 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. Meets this requirement. Pre-2016 source. Initial startup on source was 2013. Emission Inventory An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. The operator submitted for the 2023 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. 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. This source is permitted with the State of Utah with legal and enforceable limits, They do not have the production that would qualify under 40CFR (60) OOOO for a tank affected facility. PREVIOUS ENFORCEMENT ACTIONS: None in the past 5 years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to the site, the overall status is: In Compliance. This source was found to be clean and well-kept with no visible or fugitive emissions. RECOMMENDATION FOR NEXT INSPECTION: This source has a wellhead and pump jack. Production fluids are pumped to neighboring site, Stewart 2A-29-4-2 facility for process. RECOMMENDATIONS FOR NSR: None. ATTACHMENTS: None.