DAQ-2024-004922

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DAQC-PBR147200001-24
Site ID 14720 (B1)
MEMORANDUM

TO: FILE – UINTA WAX OPERATING, LLC – Gavitte 4-26-3-1E

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

FROM: Chris Jensen, Environmental Scientist

DATE: February 21, 2024

SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION

INSPECTION DATE: February 14, 2024

SOURCE LOCATION: Gavitte 4-26-3-1E
Lat:40.197993 Long: -109.857221

Business Office:
5128 Apache Plume Road, Suite 300
Fort Worth, TX 76109

SOURCE TYPE: Tank Battery
Uintah County
API: 4304752041

SOURCE CONTACTS: Aimee Cole, Local Contact
Phone: [phone], Email: [e-mail]

Kaylene Bridwell, Corporate Environmental Contact
Phone: [phone], Email: [e-mail]

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.

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SOURCE EVALUATION: Site Type: PBR- Un-Controlled
Voluntarily Controlled by Flare
Site powered by Engine

DOGM current 12 month rolling production is: 892 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. Vessel vent lines route
emissions to a combustion device. 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.

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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. UWO produced 12-month production totals. See attached.

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 before 2016 and the pumpjack engine is subject to the
performance standards in NSPS (60) JJJJ.

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. Engines installed before 2016 are no longer under obligation to retain
certifications or stack tests.
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47 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 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 Applicable Federal Regulations:

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.

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

COMPLIANCE STATUS &
RECOMMENDATIONS: In Compliance - The source was inspected 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: Email