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Home My WebLink AboutDAQ-2024-0073711 DAQC-CI145580002-23 Site ID 14558 (B1) MEMORANDUM TO: FILE – UINTA WAX OPERATING, LLC – ULT 10-26-3-1E THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Stephen Foulger, Environmental Scientist DATE: June 9, 2023 SUBJECT: PARTIAL COMPLIANCE EVALUATION, Minor, Uintah County INSPECTION DATE: April 28, 2023 SOURCE LOCATION: 40.343008 -109.744751 Uintah, UT 84078 SOURCE CONTACTS: Kaylene Bridwell, Senior Engineer. 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: Approval Order (AO) DAQE-AN145580002-15, dated October 1, 2015 SOURCE EVALUATION: Name of Permittee: Permitted Location: Uinta Wax Operating, LLC - ULT 10-26-3-1E 5128 Apache Plume Road, Suite 300 40.343008 -109.744751 Fort Worth, TX 76109 Uintah, UT 84078 SIC Code: 1311: (Crude Petroleum & Natural Gas) Section I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] Status: In Compliance. 2 I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] Status: In Compliance. AO limits were not exceeded. I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] Status: In Compliance. Modifications to source are covered under new AO approval. I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] Status: Not Observed. Partial compliance evaluation conducted at this time records were not evaluated. I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] Status: Out of Compliance. Oil tank and produced water tank thief hatches found leaking emissions at time of inspection. I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] Status: In Compliance. I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. Review of DAQ records shows emissions inventories in compliance at time of inspection. Section II: SPECIAL PROVISIONS II.B Requirements and Limitations II.B.1 Site-Wide Requirements II.B.1.a The owner/operator shall not allow visible emissions from any stationary point or fugitive emission source on site to exceed 10 percent opacity. [R307-401-8] Status: In Compliance. No visible emissions were observed at the time of inspection. II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3] Status: In Compliance. No visible emissions were observed at the time of inspection. 3 II.B.1.b The owner/operator shall only use natural gas as fuel in the pump-jack engines, boilers and heaters on site. [R307-401-8] Status: In Compliance. II.B.2 Tank Requirements II.B.2.a The owner/operator shall not produce more than 15,695 barrels (1 barrel = 42 gallons) of crude oil per rolling 12-month period. [R307-401-8] Status: In Compliance. 2,719 of production reported for the last twelve months. II.B.2.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the twentieth day of each month using the most recent 12 months of production data reported to the Utah Division of Oil, Gas and Mining. Records of crude oil production shall be kept for all periods when the plant is in operation. Crude oil production shall be determined by process flow meters and/or sales records. [R307-401-8] Status: In Compliance. DOGM records are current and reflect proper reporting. II.B.2.b The owner/operator shall load the tanker trucks on site by the use of submerged loading. [R307-401-8] Status: In Compliance. Source found using submerged loading. II.B.2.c The owner/operator shall keep the storage tank thief hatches closed and latched except during tank unloading or other maintenance activities. [R307-401-8] Status: In Compliance. Thief hatches were found closed and locked at the time of inspection. II.B.2.d The owner/operator shall inspect the thief hatches at least once every three months to ensure the thief hatches are closed, latched, and the associated gaskets, if any, are in good working condition. Records of thief hatch inspections shall include the date of the inspection and the status of the thief hatches. [R307-501] Status: Not Observed. Partial compliance evaluation conducted. No records were observed at this time. II.B.3 Pump-Jack Engine Requirements II.B.3.a The stationary engine on site shall comply with 40 CFR 60.4233(d), 40 CFR 60.4233(e), 40 CFR 60.4243(f), 40 CFR 60.4245(a) and 40 CFR 60.4245(b). [40 CFR 60 Subpart JJJJ, R307-401-8] Status: In Compliance. Section III: APPLICABLE FEDERAL REQUIREMENTS In addition to the requirements of this AO, all applicable provisions of the following federal programs have been found to apply to this installation. This AO in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including UAC R307. 4 EMISSION INVENTORY: Listed before are the Actual Emissions Inventory provided from Uinta Wax Operating, LLC ULT 10-26-3-1E. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN145580002-15, dated October 1, 2015, is provided. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 766.00 Not Reported Carbon Monoxide 2.30 1.66 Nitrogen Oxides 1.72 1.27 Particulate Matter - PM10 0.11 .03 Particulate Matter - PM2.5 0.11 .03 Sulfur Oxides 0.00 .00 Volatile Organic Compounds 4.39 1.21 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN145580002-15, dated October 1, 2015: The source was found out of compliance at the time of inspection. One crude oil thief hatch was found leaking emissions and one produced water tank thief hatch was found leaking emissions at the time of inspections. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Remain the same. The operator promptly addressed found issues and the source has dropped below 8,000 bbls of production in the rolling twelve months. ATTACHMENTS: