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Home My WebLink AboutDAQ-2024-0082861 DAQC-PBR147370001-24 Site ID 14737 (B1) MEMORANDUM TO: FILE – UINTA WAX OPERATING, LLC – Deep Creek 2-22-4-2E THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Manager FROM: Chris Jensen, Environmental Scientist DATE: June 4, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: May 22, 2024 SOURCE LOCATION: Deep Creek 2-22-4-2E Lat: 40.12857 Long: -109.75108 Business Office: 6000 Western Place Suite 1000 Fort Worth, TX 76107 SOURCE TYPE: Tank Battery Uintah County API: SOURCE CONTACTS: Kaylene Bridwell, Corporate Environmental Contact Phone: 405-496-7308, Email: kaylene.bridwell@uintawax.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, and 40 CFR 60 Subpart JJJJ, 40 CFR 60 Subpart OOOO. 2 SOURCE EVALUATION: Site Type: PBR-Uncontrolled Voluntarily Controlled by Flare Site powered by Engine DOGM current 12 month rolling production is: 2,245 BBLs. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] In Compliance. Associated gas is routed to a sales gathering line. Vessel vent lines route emissions to a combustion device. Tanks all have thief hatches and PRV's that are closed and not 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. This source does not use continuous bleed natural gas-driven pneumatic controllers. Truck loading is done by bottom filling or submerged fill pipe. [R307-504(1)] In Compliance. The truck loading area is suitable 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. The DAQ did not identify any modifications or unauthorized equipment. 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. Monthly crude production was provided. 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. This well was drilled before 2016 and the pumpjack engine is instead subject to the performance standards in NSPS (60) JJJJ. Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)] In Compliance. A record of an initial performance test was not provided to the DAQ for inspection or not kept by UWO. Engines manufactured before 2008 or installed pre-2016 are not required to maintain a performance test results for life. 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. Engines installed before 2016 are not under obligation to retain certifications or stack tests for life. 4 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 by use of the USEPA Method 9. 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. The results for the 2023 inventory have not yet been released. Applicable Federal Regulations: NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. In Compliance. The engine at this source is not certified. Stack testing may or may not have been performed but, the record retention time limit for this testing has expired. The maintenance provisions have been met. NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution. In Compliance. The tank battery at this source no longer has the production to have the PTE in excess of 4 TPY and are no longer an affected facility under this subpart. There are no other affected facilities installed. PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Deep Creek 2-22-4-2E: In Compliance - The source was surveyed by AVO and with an OGI camera and was found to be well-kept with no visible or fugitive emissions. Requested records were provided in a timely manner and reviewed at the local field 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. ATTACHMENTS: None