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Home My WebLink AboutDAQ-2024-0079011 DAQC-PBR147040001-24 Site ID 14704 (B1) MEMORANDUM TO: FILE – UINTA WAX OPERATING, LLC – Deep Creek Tribal 9-8-4-2E THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Chris Jensen, Environmental Scientist DATE: April 22, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: April 10, 2024 SOURCE LOCATION: Deep Creek Tribal 9-8-4-2E Lat:40.148327 Long: -109.785414 Business Office: 6000 Western Place, Suite 1000 Fort Worth, TX 76107-4664 SOURCE TYPE: Tank Battery Uintah County API: 4304752007 SOURCE CONTACTS: Aimee Cole, Local Contact Phone: 720-384-7365, Email: acole@finleyresources.com Kaitlin Meszaros, Corporate Environmental Contact Email: meszaros@pinyon-env.com 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. 2 SOURCE EVALUATION: Site Type: PBR- Uncontrolled No Flare Controls Site powered by Engine DOGM current 12 month rolling production is: 2,669 BBLs. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. 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. 11 Oil and Gas Industry: General Provisions [R307-501] In Compliance. Associated gas is routed to a sales gathering line. Tanks all have thief hatches and PRV's that are closed and not leaking. 13 Oil and Gas Industry: Tank Truck Loading [R307-504] In Compliance. The truck loading area is suitable for submerged loading and it is routine for truck drivers to load this way. 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. 3 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 production totals were provided. See attachment. 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 before 2016 and the pumpjack engine is subject to the performance standards in NSPS (60) JJJJ. 40 Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)] In Compliance. A record of an initial performance test was not provided to the DAQ for inspection or not kept by UWO. Engines manufactured before 2008 or installed pre-2016 are not required to maintain a performance test results for life. 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. 4 42 Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. Engines installed before 2016 are no longer under obligation to retain certifications or stack tests for life. 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. 59 NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines [40 CFR 60 Subpart JJJJ] In Compliance. The engine at this source is not certified. Stack testing may or may not have been performed but, the record retention time limit for this testing has expired. The maintenance provisions are met to comply. 5 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. The last inspection in 2019 was found to be in compliance. COMPLIANCE STATUS & RECOMMENDATIONS: In Compliance - The source was surveyed by AVO, and with an OGI camera, was found to be well-kept with no visible or fugitive emissions. 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: Engine maintenance summary Engine Service Checklist Report View Engine Service Checklist Report View Fri Apr 19 2024 06:55:37 PDT Reference Number Form Name Device Entry Time ServiceDate Facility EngineStatus MakeMod EngMake EngModel SerialCorrect SerialNumber ManufDateCorrect DateManufacture Power Band Air Filters Belts Carburetor Clutch Crank Case Engine Mounts Fuel System Grease Unit Grease Trace Grease Clutch Grease Fanhub GreaseJackShaft Hoses Leaks Lube Box Condition Oil & Filters Oil Level Regulator Radiator Reeds Safety Shutdowns Scavenger Port Spark Plug Wires Spark Plugs Starter Timing Trace System Unit Wiring Water Filters Wiring Condition 20230224- 18294966298 Engine Service Checklist 2023-02-24T09:43:57- 07:00 02/23/2023 Deep Creek Tribal 9-8-4 -2E Idle / Tracing Yes/No - Source?Arrow L-795 Yes L-600991 Yes 41000 NA Cleaned Checked, Good Checked, Good Checked, Good Checked, Good Checked, Good Checked, Good No Yes Yes Yes Yes Checked, Good Checked, Good Checked, Good Checked, Good Checked, Good Checked, Replaced Checked, Good Checked, Good Checked, Replaced Checked, Replaced N/A Checked, Good Checked, Good Checked, Good N/A Checked, Good 20230421- 18304885641 Engine Service Checklist 2023-04-21T09:19:34- 06:00 04/20/2023 Deep Creek Tribal 9-8-4 -2E Well head and Engine Hard Shut in Yes/No - Source?Arrow L-795 Yes L-600991 Yes 41000 NA Cleaned Checked, Good Checked, Good Checked, Good Checked, Good Checked, Good Checked, Good No Yes Yes Yes Yes Checked, Good Checked, Good Checked, Good Checked, Good Checked, Good Checked, Replaced Checked, Good Checked, Good Checked, Replaced Checked, Replaced N/A Checked, Good Checked, Good Checked, Good N/A Checked, Good 20221025- 18274191751 Engine Service Checklist 2022-10-25T08:22:28- 06:00 10/24/2022 Deep Creek Tribal 9-8-4 -2E Yes/No - Source?Arrow L-795 No L-600991 No NA Cleaned Checked, Good Checked, Good Checked, Good Checked, Good Checked, Good Checked, Good No Yes Yes Yes Yes Checked, Good Checked, Good Checked, Good Checked, Good Checked, Good Checked, Replaced Checked, Good Checked, Good Checked, Replaced Checked, Replaced N/A Checked, Good Checked, Good Checked, Good N/A Checked, Good 20230728- 18322454272 Engine Service Checklist 2023-07-28T08:55:33- 06:00 07/26/2023 Deep Creek Tribal 9-8-4 -2E Running under load / Pumping Yes/No - Source?Arrow L-795 Yes SN:L-600991 Yes 41000 NA Cleaned Checked, Good Checked, Good Checked, Good Checked, Good Checked, Good Checked, Good No Yes Yes Yes Yes Checked, Good Checked, Good Checked, Good Checked, Good Checked, Good Checked, Replaced Checked, Good Checked, Good Checked, Replaced Checked, Replaced N/A Checked, Good Checked, Good Checked, Good N/A Checked, Good 20231128- 18344445527 Engine Service Checklist 2023-11-28T13:39:47- 07:00 11/27/2023 Deep Creek Tribal 9-8-4 -2E Running under load / Pumping Yes/No - Source?Arrow L-795 Yes SN:L-600991 Yes 41000 NA Cleaned Checked, Good Checked, Good Checked, Good Checked, Good Checked, Good Checked, Good No Yes Yes Yes Yes Checked, Good Checked, Good Checked, Good Checked, Good Checked, Good Checked, Replaced Checked, Good Checked, Good Checked, Replaced Checked, Replaced N/A Checked, Good Checked, Good Checked, Good N/A Checked, Good 20220705- 18256331355 Engine Service Checklist 2022-07-05T09:07:30- 06:00 07/01/2022 Deep Creek Tribal 9-8-4 -2E Yes/No - Source?Arrow L-795 Yes L-600991 Yes 41000 NA Cleaned Checked, Good Checked, Good Checked, Good Checked, Good Checked, Good Checked, Good No Yes Yes Yes Checked, Good Checked, Good Checked, Good Checked, Good Checked, Good Checked, Replaced Checked, Good Checked, Good Checked, Replaced Checked, Replaced N/A Checked, Good Checked, Good Checked, Good N/A Checked, Good Page 1