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HomeMy WebLinkAboutDAQ-2024-007188 1 DAQC-PBR146350001-23 Site ID 14635 (B1) MEMORANDUM TO: FILE – UINTA WAX OPERATING, LLC – Deep Creek 7-27-4-2E THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Manager FROM: Stephen Foulger, Environmental Scientist DATE: August 25, 2023 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: July 19, 2023 SOURCE LOCATION: Deep Creek 7-27-4-2E Lat:40.10913 Long: -109.7517 Business Office: 5128 Apache Plume Road, Suite 300 Fort Worth, TX 76109 SOURCE TYPE: Tank Battery Uintah County API: 4304754258 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 OOOO. SOURCE EVALUATION: Site Type: PBR- Controlled Controlled by flare Site powered by Engine The source registered: 95000 Estimated Oil BBL. 2 DOGM current 12 month rolling production is: 2911. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Engine – No info Provided, Pneumatic, Tank Oil and Gas Industry Registration Requirement The source is registered with the DAQ. [R307-505-3(3)] In Compliance. Search of DAQ records shows source is properly registered 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. Search of DAQ records shows source is properly registered Storage Vessels Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. Thief hatches found closed and latched at the time of inspection. Upon modification, the well site was re-evaluated against the thresholds of R307-506-4(2). [R307-506-4(6)] In Compliance. Source was found unmodified at the time of inspection. 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. DAQ inspector has reviewed these documents and found them compliant. 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. 3 Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)] Out of Compliance. Operator failed to produce these required documents. 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] Out of Compliance. Operator failed to produce these required documents. 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 emission observed at the time of inspection. Emission Inventory: An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. DAQ records show emissions inventory has been submitted. NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution [40 CFR 60 Subpart OOOO] In Compliance. PREVIOUS ENFORCEMENT ACTIONS: Compliance advisory issued 01/31/2020 to previous owners Crescent Point Energy. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to: Deep Creek 7-27-4-2E: Out of Compliance - This source was found non-compliant and is voluntarily controlled. Recommend to keep the inspection frequency the same due to decreased production and voluntary control. No issues were found on-site; non-compliance status is due to missing records. RECOMMENDATION FOR NEXT INSPECTION: Memo: Recommend to keep the inspection frequency the same due to decreased production and voluntary control. No issues were found on-site; non-compliance status is due to missing records.