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Home My WebLink AboutDAQ-2024-0048471 DAQC-PBR146990001-24 Site ID 14699 (B1) MEMORANDUM TO: FILE – UINTA WAX OPERATING, LLC – Kendall 11-8-3-1E THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Chris Jensen, Environmental Scientist DATE: January 25, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: January 17, 2024 SOURCE LOCATION: Kendall 11-8-3-1E Lat: 40.23609809 Long: -109.91006791 Business Office: 5128 Apache Plume Road, Suite 300 Fort Worth, TX 76109 SOURCE TYPE: Tank Battery Uintah County API: 43047-52894 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. SOURCE EVALUATION: Site Type: PBR Voluntarily Controlled by Flare Site powered by Engine DOGM current 12 month rolling production is: 614 BBLs. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. 2 REGISTERED EQUIPMENT: 8 Pneumatic Controllers 9 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. 15 Oil and Gas Industry Registration Requirement 16 The source is registered with the DAQ. [R307-505-3(3)] In Compliance. 17 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. 18 Storage Vessels 19 Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. All hatches were found closed at the start of the evaluation. 23 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. 24 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 totals of production were given. 38 Natural Gas Engines 39 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 prior to 2016 and the engine is assumed to also been installed prior to 2016. The DAQ assumes this source is not subject to these emissions standards but, may be subject to the standards found in NSPS (60) JJJJ. See evaluation below. 3 40 Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)] Out of Compliance. No performance test is found in DAQ records nor has UWO provided one. 41 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. 42 Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] Not Applicable. It is likely that the engine installed here is not subject to this recordkeeping regulation as the engine was likely installed before 2016. 46 Visible Emissions 47 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. 55 Emission Inventory: 56 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. Applicable Federal Regulations: 59 NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines [40 CFR 60 Subpart JJJJ] Out of Compliance. The engine at this source has not been performance tested and is not a certified engine. The DAQ cannot determine if the emissions are within the standards to comply with this subpart. An absence of this document does not meet the recordkeeping provisions of this subpart. The recordkeeping and engine maintenance requirements are not being met. If the engine was manufactured prior to 2008 this engine is not subject to this regulation but NSPS (60) ZZZZ that has engine maintenance and recordkeeping provisions that are not being met. UWO has not provided a date of manufacturer for this engine for the DAQ to determine applicability. PREVIOUS ENFORCEMENT ACTIONS: The previous owner was issued a CA for a smoking pump jack engine late 2018. COMPLIANCE STATUS & RECOMMENDATIONS: Out of Compliance – UWO is not performing testing, recordkeeping, and engine maintenance or is not providing the DAQ with access to those records for review. UWO is not providing applicability, by way of a manufacture or installation dates. The DAQ has deemed inspection of a tag with the date of 4 manufacture on a running engine to be a safety risk and did not attempt to determine the date of manufacture during the evaluation. Due to the ongoing joint NOV for previous engine violations with the USEPA, no further enforcement action is taken by the DAQ for engine related violations. 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