DAQ-2024-007360

1
DAQC-CI146950001-23
Site ID 14695 (B1)

MEMORANDUM

TO: FILE – UINTA WAX OPERATING, LLC – Deep Creek 1-27-4-2E

THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager

FROM: Stephen Foulger, Environmental Scientist

DATE: September 14, 2023

SUBJECT: OIL AND GAS APPROVAL ORDER EVALUATION

INSPECTION DATE: July 19, 2023

SOURCE LOCATION: 40.13048418 -109.74639322
Uintah, 84000
SOURCE CONTACTS: Kaylene Bridwell, Corporate Environmental Contact
Phone: [phone], Email: [e-mail]
Jason Lachance, Surface Tech. Manager
Phone: [phone], Email: [e-mail]

OPERATING STATUS: No previous compliance action was found in the past five years.

PROCESS DESCRIPTION: A heater treater will separate the oil, water, and gas. The oil and
water will be stored in tanks prior to being transported off-site by
trucks. The gas will be used as fuel for the onsite equipment or
will be routed to a sales pipeline and shipped off-site. This
facility will process up to 64,970 barrels of crude oil per year.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN146950002-14 dated
September 11, 2014

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Uinta Wax Operating, LLC – Deep Creek 1-27-4-2E
5128 Apache Plume Road, Suite 300 40.13048418 -109.74639322
Fort Worth, TX 76109 Uintah, 84000

SIC Code: 1311: (Crude Petroleum & Natural Gas)

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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: Not Applicable.

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

Status: Out of Compliance. Source permitted for 1.1 MMBtu for burners and
boilers. 2 MMBtu found at the time of inspection.

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: Out of Compliance. Burners found changed out. This change brought
MMBtu levels to a non-compliant level.

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: Out of Compliance. No engine certification was suppled.

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: In Compliance. Pollution controls found in proper working order.

I.6 The owner/operator shall comply with UAC R307-107. General Requirements:
Breakdowns. [R307-107]

Status: In Compliance. No breakdowns were reported.

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

Status: In Compliance. Search of DAQ records shows emissions inventory properly
reported.

Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.B Requirements and Limitations

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II.B.1 Site-Wide Requirements.

II.B.1.a The owner/operator shall notify the Director in writing when the equipment listed in this
AO has been installed and is operational. To ensure proper credit when notifying the
Director, send your correspondence to the Director, attn: Compliance Section.

If the owner/operator has not notified the Director in writing within 18 months from the
date of this AO on the status of the construction and/or installation, the Director shall
require documentation of the continuous construction and/or installation of the operation.
If a continuous program of construction and/or installation is not proceeding, the Director
may revoke the AO. [R307-401-18]

Status: In Compliance.

II.B.1.b Unless otherwise specified in this AO, 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.b.1 Unless otherwise specified in this AO, 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.

II.B.2 Tank Requirements.

II.B.2.a The owner/operator shall not produce more than 64,970 barrels (1 barrel = 42 gallons) of
crude oil per rolling 12-month period. [R307-401-8]

Status: In Compliance. 2,051 barres of production have been reported in the last 12
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 data from the previous 12
months. 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. The records of crude oil production shall be kept on a daily basis. [R307-401-8]

Status: In Compliance. Production records found properly reported.

II.B.2.b At least once each month, the owner/operator shall inspect each closed vent system
(including tank openings, thief hatches, and bypass devices) for defects that could result in
air emissions according to 40 CFR 60.5416a(c). Records of inspections shall include the
date of the inspection and the results of the inspection. [R307-401-8, 40 CFR 60 Subpart
OOOOa]

Status: In Compliance. These records were reviewed by DAQ and found to be
compliant at the time of inspection.

II.B.2.c The owner/operator shall load the tanker trucks on site by the use of submerged loading.
[R307-401-8, R307-504-4]

Status: In Compliance. Source set up for submerged loading.

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II.B.2.c.1 The owner/operator shall keep the storage tank thief hatches and other tank openings closed
and sealed except during tank unloading or other maintenance activities. [R307-401-8]

Status: In Compliance. Thief hatches found closed and sealed at the time of
inspection.

II.B.3 Combustor/Flare Requirements.

II.B.3.a Each combustor shall operate with a continuous pilot flame and be equipped with an
auto-igniter. [R307-503-4]

Status: In Compliance. Flare found lit and operating at the time of inspection.

II.B.3.b Each combustor shall operate with no visible emissions. [R307-401-8]

Status: In Compliance. No visible emissions were observed at the time of inspection.

II.B.3.b.1 Visual determination of emissions from each combustor shall be conducted according to
40 CFR 60, Appendix A, Method 22. [R307-401-8]

Status: In Compliance. No visible emissions were observed at the time of inspection.

II.B.4 Engine Requirements.

II.B.4.a The distance from the pumpjack engine to the property boundary (the edge of the pad) shall
not be less than 50 meters. [R307-410-5]

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.
AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

EMISSION INVENTORY:

Listed before are the Actual Emissions Inventory provided from Uinta Wax Operating, LLC –
Deep Creek 1-27-4-2E. A comparison of the estimated total potential emissions (PTE) on
DAQE-AN146950002-14 dated September 11, 2014. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 875.00
Carbon Monoxide 5.43 1.87
Nitrogen Oxides 2.33 1.54
Particulate Matter - PM10 0.12 0.07
Particulate Matter - PM2.5 0.12 0.07
Volatile Organic Compounds 11.43 1.81

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PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN146950002-14
dated September 11, 2014:

Attached is the compliance advisory sent by DAQ, the operator's
written response, and the NFA sent by DAQ.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: The source was found non-compliant with the issued AO at the
time of inspection. The Operator has submitted this source for
AO revocation. No emissions leaks were found on-site, the
source will be voluntarily controlled once its status is changed to
PBR. Recommend to keep inspection frequency the same.

ATTACHMENTS: Applicable Supporting Documentation Included
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
SPENCERJ. COX. Governor
DEIDRE HENDERSON
Lieutenant Governor
DAQ-2023-008074
August 24,2023 DAQC-869-23
Site 14695 (B1)
Sent Via Certified Mail No. 70190700000208345804
Kaylene Bridwell
Uinta Wax Operating, LLC
5128 Apache Plume Road, Suite 300
Fort Worth, Texas 76109
Dear Kaylene Bridwell:
Re: Compliance Advisory - Uinta Wax Operating, LLC, DAQE-AN146950002-14, Uintah
County
On July 19,2023, a representative of the Utah Division of Air Quality (DAQ) conducted an
inspection of Uinta Wax Operating,LLC, Deep Creek l-27-4-28. During the inspection, tank
heaters exceeded permitted 1.1 MMBtu lkr by .9 MMBtu/hr; all of which may be violation(s) of
DAQE-ANt46950002-t4.
Uinta Wax Operating, LLC is required to comply with the above regulations. A written response
to this letter is required within ten (10) business days of receipt of this leffer.
Additional details about the above observations and regulations are affached to this letter. Please
contact Stephen Foulger at [phone] or [e-mail] if you have any questions about
this letter.
Sincerely,
, /,/( --1)- ^-
Rik Ombach, Manager
Minor Source Oil and Gas Compliance Section
RO:SF:rh
cc: TriCounty Health Department
195 North 1950 West. Salt Lake City, UT
Mailing Address: P.O. Box 144820. Salt Lake City, UT 84114-4820
rerephone (80r) s364000 .r#:r:il":::#te. r.D.D. (80r) e03-3e78
Printed on 100% recycled paper
DAQC-869-23
Page2
Potential Violation(s)
On July 19,2023, an inspector from the DAQ observed Uinta Wax Operating, LLC at Deep
Creek l-27-4-28 in Uintah County, Utah.
At the time of the inspection the DAQ documented the following potential violations:
o .) MMBtr/hr over permitted 1.1 MMBtu/hr allowed for heaters/boilers.
AO Conditions/Rules
DAQE-AN146950002-14:
o Equipment: Boilers: Various Boilers/Ileaters: Rated Capacity:1.1 MMBtulhr
combined. Fuel: Natural Gas.
The purpose of a Compliance Advisory (CA) is to document observations made by the DAQ. You
are responsible for complying with the Utah Air Conservation Rules. There are possible
administrative and civil penalties for failing to do so. Section 19-2-115 of the Utah Code
Annotated provides that violators of the Utah Air Conservation Act and/or any order issued there
under may be subject to a civil penalty of up to $10,000 per day for each violation.
The written response to this CA will be considered in resolving the deficiencies documented in
this letter. It may include information demonstrating compliance with the regulations or a
schedule to bring your company back into compliance with the applicable regulations. The DAQ
will review your response and this CA may be revised as a result of that review. Failure to
respond in writing within ten (10) business days of receipt of this CA will be considered in any
subsequent enforcement action and the assessment of penalties.
Possible DAQ actions to resolve a CA include: No Further Action Letter, Waming Letter, Early
Administrative Settlement with reduced civil penalty, Settlement Agreement with civil penalty, or
Notice of Violation and Order to Comply.
This CA does not limit or preclude the DAQ from pursuing enforcement options concerning this
inspection. Also, this CA does not constitute a bar to enforcement action for conditions that the
DAQ did not observe or evaluate, or any other conditions found during future inspections.
A meeting may be requested to discuss this CA. Please contact Stephen Foulger at
[e-mail] or [phone] if you would like to request a meeting or if you have any
questions about this letter.
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1. MicleAddressedto:
KA\.EENE BRIDWELL
UINTA WAX OPERATING, LLC
5128*4PACHE PLUME ROAD, SUrrE 3oo
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UINTA WAX, LLC
PO BOX 101868
FORT WORTH, TX 76185

OFFICE FAX
[phone] [phone]
September 8, 2023
Rik Ombach
Manager
Minor Source Oil and Gas
Compliance Section
195 North 1950 West
PO Box 144820
Salt Lake City, UT 84114-4820

RE: Compliance Advisory- Uinta Wax Operating LLC, DAQE-AN146950002-14, Uintah County
Dear Mr. Ombach,
On August 29, 2023, Uinta Wax Operating, LLC received a compliance advisory letter dated August 24,2023. The letter
stated tank heaters exceeded permitted 1.1 MMBtu/hr by .9 MMBtu/hr as observed during an onsite inspection date of July
19,2023. Uinta Wax acknowledges receipt of this letter and provides the following response.
Uinta Wax Operating, LLC submitted a request for the Deep Creek 1-27-4-2E AO to be revoked and the location be
permitted as permit by rule (PBR) on August 14, 2023. Uinta Wax Operating, LLC has not increased burner capacity at
this site since acquiring the asset from Cresent Point Energy in November 2019.
Unita Wax respectfully asks that a more detailed follow-up response be allowed if needed.
Please contact me directly at [e-mail] or 405.496.7308 with questions or concerns.

Sincerely,

Kaylene Bridwell
Senior Engineer
Uinta Wax Operating, LLC
5128 Apache Plume Road, Suite 300
Fort Worth, Texas 76107
[e-mail] / 405.496.7308

CC: Stephen Foulger, Environmental Scientist UDAQ
Jason Pearce, Uinta Wax President
Karen Pratt, Regulatory Manager
Jason Lachance, Facilities Manager
Josh Morgan, Air Compliance