DAQ-2024-007416

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DAQC-PBR147280001-23
Site ID 14728 (B1) MEMORANDUM

TO: FILE – UINTA WAX OPERATING, LLC – Kendall 13-17-3-1E

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

FROM: Chris Jensen, Environmental Scientist

DATE: December 18, 2023

SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION

INSPECTION DATE: December 13, 2023

SOURCE LOCATION: Kendall 13-17-3-1E
Lat: 40.217269 Long: -109.913897

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

SOURCE TYPE: Tank Battery
Uintah County
API:

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.

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

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DOGM current 12 month rolling production is: 3,112 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 December 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.

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. Production totals were computed and delivered to the DAQ.

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 source was drilled in 2014 and is not subject to this rule's standards.
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40 Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)]

In Compliance. UWO does not retain records of performance testing longer than 5 years. The
well at this source was drilled in 2014, and lifetime retention of stack testing does not apply.

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]

In Compliance. The well at this source was drilled in 2014, and lifetime retention of stack testing
does not apply.

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. UWO does not retain records past 5 years. The engine (Arrow L-795) at this
source may not have 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. Engine
maintenance was conducted 3 times this past year.

PREVIOUS ENFORCEMENT
ACTIONS: The previous operator answered to a Compliance Advisory
(DAQC-2142-18) for leaking thief hatches and pressure
transducer.

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.

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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