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Home My WebLink AboutDAQ-2024-0048481 DAQC-PBR147030001-24 Site ID 14703 (B1) MEMORANDUM TO: FILE – UINTA WAX OPERATING, LLC – Womack 1-7-3-1E THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Chris Jensen, Environmental Scientist DATE: January 23, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: January 17, 2024 SOURCE LOCATION: Womack 1-7-3-1E Lat: 40.24083 Long: -109.918159 Business Office: 5128 Apache Plume Road, Suite 300 Fort Worth, TX 76109 SOURCE TYPE: Tank Battery Uintah County API: 43047-53089 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: 2,118 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. The production totals are the only one of these that are required to be kept and the DAQ was given them. 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)] Not Applicable. This well was drilled in 2015 so the Arrow pump jack engine installed here is assumed to have been installed pre-2016 and not likely subject to these emissions standards but the standards in NSPS (60) JJJJ. See that 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. Record of an initial performance test was not provided to the DAQ for inspection or is not kept by UWO. 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] Out of Compliance. A record of an initial performance test was not provided to the DAQ for inspection or not kept by UWO. Engines installed pre-2016 are not required to maintain a performance test results for life. UWO has not provided dates of manufacture or installation for the DAQ to evaluate compliance with this rule. 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 (Arrow L-795) at this source has not been shown to have been performance tested and it is not a certified engine. UWO did not provide a date of manufacture for this pumpjack engine. Without this the DAQ cannot determine applicability or compliance. The DAQ has asked for and has not been provided engine maintenance records as well. An engine manufactured after 2008 is subject to the recordkeeping requirements of this subpart. PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to: Womack 1-7-3-1E: Out of Compliance - A survey with an OGI camera returned leaking components on the associated gas line side in the treater shed. This condition does not meet the standard of maintained in 4 a manner to minimize emissions [UAC R307-501]. The DAQ has not yet received verbal or written confirmation of the repair of these fugitive emissions. UWO has not provided any of the documents (dates of manufacture, dates of installation, engine maintenance plan, and engine maintenance records) required to demonstrate compliance with UAC R307-510 or NSPS (60) JJJJ or is not keeping those records, in violation of NSPS (60) JJJJ. The DAQ recommends that UWO answer to a compliance advisory and present the dates of installation and manufacture in defense of their recordkeeping practices. UWO should also confirm the repair of the leaking components. 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